PAGE 1 OF 9 1. Purpose The purpose of this program is to establish minimum requirements and procedures for the safety and health of employees and contractors working at the Lake Charles facility who must work in and around confined spaces. 2. Scope This program applies to all of Lake Charles complex. It provides minimum safety requirements to be followed while entering, exiting and working in confined spaces. It applies to PPG as well as non-ppg employees. 3. Responsibilities PPG Management is responsible for the overall support of the Confined Space Program. PPG Operations and Maintenance managers are responsible to ensure that this program is followed by everyone, PPG or not, working in the Lake Charles Complex. Area Compliance Personnel are responsible for ensuring that the confined space matrix is current. Any changes, addition or deletion to the confined space matrix will trigger a Management of Change process. The Safety department is responsible for the overall program; procedure, confined space matrix monitoring and safety requirements, audit and evaluation of spaces. The emergency response coordinator is responsible to evaluate the space for rescue considerations. Shift safety is responsible, if requested; to evaluate and document on the permit any relaxed rescue considerations and initial comments as to the reason for the downgrade. 4. Procedure Entry Supervisor Responsibilities: Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure (See Sections 1, 2, & 3 of the Permit) Identify the Space and the purpose of the entry. Identify the previous contents of the space to be entered Identify all potential hazards associated with the space to be entered Ensure the area surrounding the confined space will not create an exposure to other personnel in the immediate surrounding area by the activities conducted in the confined space. If necessary, barricades shall be erected per the requirements of Plant Barricades (DOCUMENT #: 4301-06- 343). The opening shall be posted with a "Danger - Permit Required Confined Space - Do Not Enter" sign. Once the entrance way has been opened, a physical barricade or guard must be placed at the entrance to secure the space from unauthorized entry. If a radiation source is involved contact the Radiation Safety Officer. Verify, by checking that the appropriate entries have been made on the permit, that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before signing the permit. (See Section 4 of the Permit) Verify that the Atmospheric Testing was completed and acceptable for entry Ensure that Atmospheric testing is done as prescribed on the confined space matrix.. o If it is a first entry, ensure that the clearing sample, if required, was taken and the space is clear for entry. o If it is not a first entry: write down the initial permit number, verify the date and conditions under which the first permit was issued is still valid.
PAGE 2 OF 9 o A continuing permit cannot be issued if the conditions in or surrounding the space have changed, if new hazards have been introduced or there is a potential of new hazards. o A continuing permit cannot be issued if the space has been unoccupied for more than 120 hours (5 calendar days) or otherwise specified on the confined space matrix. Identify monitoring equipment used; ensure calibration is current and that the equipment was bump tested. Ensure acceptable entry conditions exist prior to space entry (i.e. Oxygen Content, Lower Explosive Limit, Contaminants, and Residual of prior contents in the space). Entry is not to be done until all acceptable conditions exist. (Per section # 4, Atmospheric Monitoring) Routine O2/LEL monitoring will be conducted every two hours and the results must be recorded on the permit. If continuous O2/LEL monitoring is required by the confined space matrix or the introduction of a hazard (I.e. welding, lining, etc.), results must be recorded on the permit every two hours. Retesting of the space will be done if the space has remained unoccupied for more that 30 minutes. Document this on the permit with time and results. If routine or continuous O2/LEL monitoring results fail to meet acceptable entry conditions, the space must be evacuated if occupied and re-evaluated. Evaluate the space in terms of atmospheric conditions. If ventilation cannot bring the space into acceptable entry conditions, respiratory protection will be required. If you have any questions about establishing ventilation, (i.e. if it is reasonable to expect hazardous atmospheres to be present or created in the permit required confined space) consult with Industrial Hygienist. If cooling tower entry is to occur, ensure legionella tests are completed. (Refer to EDM Document # 4301-06-488, Legionella Control Program) Verify that hazard prevention measures are in place (See Section 5 of the Permit) Ensure that the permit-required confined space is drained, purged, and cleared. If the space cannot be cleared with reasonable effort, consult with the Safety Department. Assure you have an approved isolation checklist for any confined space entry. If it is a first entry, ensure that all lockout and isolation points are checked. After which a job verified tag must be properly issued and attached to the appropriate lock box. Write down on the permit the seal numbers of the job verified tag. If it is not a first entry, ensure lock-out and isolation points are still valid: verify that the seal numbers on the lockout and isolation boxes are the same as the Job Verified Tag number. If so, record the seal numbers on the confined space permit. If a seal number of a lock box does not match the job verified tag, the permit cannot be issued without a revalidation of the lockout, isolation and atmospheric conditions. Blinds Installed, Spools Removed, Piping Misaligned, or Double Block & Bleed may be used on non-hydrocarbon and non-gaseous systems provided the low point bleed remains open and locked. Verify the equipment needed (See Sections 6-9 on permit) Ensure that all specified equipment needed is provided. Because the compressed plant air could be contaminated, it shall not be used to ventilate either directly or indirectly. Venturi effect is acceptable if air is drawn out of the space (i.e. air horn). A stand alone compressor should be used with direct ventilation or when operating pneumatic tools inside of a space. Verify that rescue services are available and that the means for summoning them are operable (See Section 7 on Permit) Ensure that all rescue equipment is set up as prescribed in the confined space matrix for the identified space. The matrix is located on the Lake Charles Intranet Home Page. Any additions,
PAGE 3 OF 9 changes or modifications to the matrix should be initiated prior to entry, using an MOC, through your Compliance Coordinator and validated by your area safety representative. Where the use of rescue equipment itself (i.e. lifelines) could create a hazard, lifeline requirements may be waived by a written evaluation from Shift Safety or Area Safety Representative. Entry Supervisor shall verify the ability to summon the E-Squad by contacting the Main Guard Office at 708-4242 and providing the following information: Space to be entered, Start time and duration of the permit, Location, Entry Supervisor s name and contact number. Ensure that only authorized personnel enter the confined space. Only the Confined Space Entry Supervisor can authorize entry into the space. Rescue personnel are automatically authorized if an emergency situation should arise. Assure that no one is assigned as an attendant or authorized entrant if their training is not current. Instruct the attendant that only authorized entrants are to enter the space. All other possible entryways or exits are secured so that entrance can only be made through a monitored access. To maintain continuity of the operations within a confined space or whenever it is necessary to reassign responsibility as the Confined Space Entry Supervisor, certain conditions must be met. After initial issuance of the permit, the Entry Supervisor responsibilities can be transferred to another Supervisor should the need arise and acceptable to both supervisors. They would then become the Confined Space Entry Supervisor. The transfer of responsibility will only be for the original duration of the permit (or sooner if the permit is terminated). This transfer of responsibilities must be noted on the Approval (Signature) section of the permit. If the work inside the confined space goes beyond one shift and the same crew is working inside the space, the permit may be extended to a maximum of two hours. If a new crew is taking over the work inside the space, a new permit is required. On the new entry permit the entry supervisor must review the spaces initial permit and assure that condition remain acceptable for entry. The initial permit is used as a guide. Document the initial entry permit s number on the new entry permit. Verify that the blue seal number on the lock box and the recorded number on the confined space permit is still the same. Document the seal number on the new entry permit. The entry supervisor shall terminate entry at the completion of the allotted time on the permit or a condition that is not allowed under the entry permit arises in or near the permit space. All confined space entries require a permit authorization signature from the Entry Supervisor. Permits should only be signed after the Entry Supervisor has verified and been made aware of all isolation points, monitoring data, and special hazards. Permits shall be posted at the jobsite. Terminate the entry whenever entry conditions are not maintained or the permit duration has elapsed. If the permit is terminated the space must be re-evaluated and re-permitted. Anytime the space is unoccupied, the Entry Supervisor shall ensure that the entryway is guarded by an attendant or by a temporary cover (physical barrier) that will prevent unauthorized entry. The cover must contain a sign stating "Danger - Permit Required Confined Space - Do Not Enter" sign. If the permit is terminated prior to the end of the shift (i.e. for an evacuation), the Entry Supervisor shall write the word TERMINATED across the face of the permit and note the reason for termination. (Note: To be completed by PPG Job Supervisor when contractors are involved.) A new permit must be issued if work is to begin again as safe entry conditions may have changed. You are required to return the completed permit to Operations. They will then forward the permit to the Safety Department.
PAGE 4 OF 9 PPG Job Supervisor Utilizing Contractors Review the Confined Space Entry Permit with the Contractor. Assure that the contractor person who is designated as the Contractor Entry Supervisor has been trained to the level required by 29 CFR 1910.146(g) (3). Assure the contractor use only personnel trained in confined space entry. Note confirmation on the permit. Ensure equipment is available as identified on the Confined Space Entry Permit. Contractors will furnish their own equipment necessary to do the job. (Includes tripods, harnesses, etc.). 29 CFR 1910.146(k) (3) except for the method for summoning the PPG Job Supervisor (such as a radio). Contractors will be responsible to provide air monitors for continuous O2/LEL monitoring and use acceptable methods to assure entry conditions remain acceptable. Evacuation must be done until condition can be made acceptable again. The PPG Job Supervisor will be notified immediately should an evacuation become necessary. Contractor will be notified and given the opportunity to observe the testing of the space using methods outlined 29 CFR 1910.146(d) (5) (iii) and (iv) The PPG Job Supervisor (unit, maintenance or field engineering) is required to walk through and personally identify control points with the Contractor Entry Supervisor who will complete the Contractor Job Verified Tag. Place the tag on the lock box. Ensure that information on the potential hazards that might be encountered in the space including the method, signs or symptoms, and consequences of exposure to any residual chemicals are relayed to the Contractor Entry Supervisor. This can be done from a Material Safety Data Sheet. Ensure that the work conducted by the contractor does not create a hazard in the space that is not addressed or monitored. The PPG Job Supervisor and Contractor Entry Supervisor sign and date the Confined Space Entry Permit. Anytime the space is unoccupied, the Contractor Entry Supervisor shall ensure that the entryway is guarded either by an attendant or by a temporary cover (physical barrier) that will prevent unauthorized entry. The cover must contain a sign stating that this is a "Danger - Permit Required Confined Space - Do Not Enter" sign. Re-sampling for O2/LEL will be done if the space is unoccupied for more than 30 minutes. Consult with the PPG Job Supervisor. After the permit has been terminated, review the entrance activities with the contractor noting any additional hazards noticed or created with the work that was done. Document all pertinent information on the back side of the Confined Space Entry Permit (comment section) and sign & date. Attendant Responsibilities Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure. Be aware of possible behavioral effects of hazard exposure in authorized entrants; Continuously maintain an accurate count of authorized entrants in the permit space. Remain outside the permitted space during entry operations until relieved by another qualified attendant. Note the name, date and time of the relief on the permit. Under no circumstances will attendant leave the immediate area while the permit-required confined space is occupied. There shall be no other duties or responsibilities that could interfere with their primary duty to the safety of the entrants. o The attendant shall sign and date the back of the confined space permit and wear the orange vest indicating they are the assigned attendant. o The attendant shall ensure that the name of all authorized entrants and entry/exit time is entered onto the back of the confined space permit or the confined space roster. Communicate with authorized entrants (i.e., visual, voice, radio.) as necessary to monitor entrant status and to alert entrants of the need to evacuate the space if necessary.
PAGE 5 OF 9 Monitor activities inside and outside the space to determine if it is safe for entrants to remain in the space and orders the authorized entrants to evacuate the permit space immediately under any of the following conditions; o If the attendant detects a prohibited condition (area monitor alarm goes off); o If the attendant detects the behavioral effects of hazard exposure in an authorized entrant; o If the attendant detects a situation outside the space that could endanger the authorized entrants (lightening, evacuation, etc); or o If the attendant cannot effectively and safely perform all the duties required Summon rescue and other emergency services as soon as the attendant determines that authorized entrants may need assistance to escape from permit space hazards; Notify the control room prior to initial entry via radio when the space is initially permitted or repermitted with information on the location of the confined space, expected number of entrants and estimated completion. This is notification and assurance that the communications device works. Make the determination that, if an emergency condition exists in an adjacent area of the facility (i.e. an alarm is sounded in another part of the facility) that could affect the entrants, terminate the confined space entry operations immediately. Performs non-entry rescues as specified by the employer's rescue procedure; and In the event of an emergency that requires the rescue of entrants, the attendant shall use the portable radio to contact the control room. The attendant shall remain at the site (unless he/she is also in immediate danger) to relay information regarding the emergency. Takes 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 persons 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; The attendant shall deny entry into the space if it has been vacated for greater than 30 minutes and follow-up sampling has not been completed. Entrant Responsibilities Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure; o Understand all requirements of the permit required confined space procedure and ask questions if unsure. o Request observation and/or participation in the atmospheric monitoring of the confined space, if desired. o The entrant must never enter a permit-required confined space if they are not authorized by the Entry Supervisor or the space is not properly permitted. o The entrant must utilize the equipment necessary to do the job safely. This includes prescribed PPE as well as the proper tools for the job at hand. o Comply with all lockout requirements, as applicable per Lockout Procedure (SP #6), as an authorized employee. o The entrant must never leave welding/cutting torches or hoses in the space while unoccupied, unless said hoses have been physically disconnected at the regulator. Bottles must remain outside the space at all times. Properly use equipment provided for the entry o Testing and monitoring equipment o Ventilating equipment
PAGE 6 OF 9 o Communications equipment o Personal protective equipment o Lighting equipment o Equipment, such as ladders, needed for safe ingress and egress by authorized entrants; Rescue and emergency equipment o Any other equipment necessary for safe entry into and rescue from permit spaces. Communicate with the attendant as necessary to enable the attendant to monitor entrant status and to enable the attendant to alert entrants of the need to evacuate the space o Never enter the space without an authorized attendant present. o Ensure, as an entrant, that your name and entry/exit times are properly logged on the back of the confined space entry permit. Alert the attendant whenever: o The entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or the entrant detects a prohibited condition; and o Exit from the permit space as quickly as possible whenever an order to evacuate is given by the attendant or the entry supervisor, o Exit the space if the entrant recognizes any warning sign or symptom of exposure to a dangerous situation, the entrant detects a prohibited condition, or an evacuation alarm is activated. Permit Review After completion of all permit required confined space work, the permit shall be forwarded to Area Safety Representative. Upon receipt, all permits shall be reviewed with specific deficiencies addressed with the personnel involved. Safety personnel will maintain all terminated permits for a one-year period and will be evaluated to identify needed changes in the plant s entry procedures or necessary retraining. 5. Confined Space Training All PPG personnel involved in confined space operations, either as an attendant, entrant, or Entry Supervisor shall complete training before participating in any aspect of permit required confined space work program. Retraining shall take place whenever there is a change in permit required confined space procedure. Operations that present a hazard on which an employee has not previously been trained or whenever there is reason to believe that there are either deviations from permit space entry procedures or that there are inadequacies in employee knowledge of these procedures. Contractor employers are responsible for ensuring that contractor employees are properly trained in confined space entry operations as required by OSHA. PPG will communicate PPG-specific requirements to contractor employees as part of the job planning process. The Safety Department shall train and equip an in-house rescue team for conducting confined space rescues. This team is the plant Emergency Squad. E-Squad members shall be trained annually on confined space rescue concepts. As part of this training, E-Squad members shall perform simulated rescues in spaces that are representative of the types of spaces routinely entered at the plant. Additionally, all E-Squad members shall be trained in First-Aid and CPR. Supervisor of Emergency Response will evaluate rescue training resources to ensure that their qualifications are appropriate for the training material presented. Confined Space Matrix The Lake Charles Facility will maintain a Permit Required Confined Space matrix. Area Compliance Personnel will be responsible for keeping the matrix current and accurate. This is an evaluation tool used to reasonably deduce if a space meets the definition of being a Permit-Required Confined Space.
PAGE 7 OF 9 Once the space has been determined, it will have listed the initial provisions for rescue, (i.e. Harness, Lifeline, Tripod, etc.). This will allow the individual issuing a permit to have an understanding of the rescue requirements of that space. If the space is downgraded from a PRCS permanently, the matrix will be changed to reflect that and an MOC written stating why the change was made. 6. Definitions Authorized Attendant - An individual stationed outside one or more permit spaces who monitors the authorized entrants and who performs all attendant's duties assigned in the employer's permit space program. Authorized Entrant - An employee who is authorized by the Entry Supervisor to enter a permit space. Blinding/Blanking - The absolute closure of a pipe, line, or duct by the fastening of a solid plate (such as a spectacle blind or a skillet blind) that completely covers the bore and that is capable of withstanding the maximum pressure of the pipe, line, or duct with no leakage beyond the plate. This is one of the 3 acceptable means of piping isolation for confined space entry. Confined Space A space that possesses each of the following characteristics: Is large enough and so configured that an employee can bodily enter and perform work; and Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults and pit that may have limited means of entry); and Is not designed for continuous employee occupancy. Confined Space Entry - The action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that 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. Contractor Entry Supervisor - The supervisor employed by the contract company (or senior contract company employee on the job site) responsible for the contractors entering a confined space. If Contract Company does not have a supervisor or senior employee on site, then the PPG Job Supervisor responsible for the contract service will serve as the contract employee s entry supervisor. Double Block and Bleed - the closure of a line, duct, or pipe by closing and locking or tagging two in-line valves and by opening and locking or tagging a drain or vent valve in the line between the two closed valves. This is one of the 3 acceptable means of piping isolation for confined space entry. Electrical Equipment Electrical equipment used within a confined space must be low voltage. Explosion proof or intrinsically safe electrical equipment is to be used in confined spaces that previously contained a Flammable or Combustible material under normal operation (Refer to MSDS). All corded electrical equipment must be used with a GFCI. 110 volt lighting with a GFCI can only be used in confined spaces that under normal operation or shutdown conditions does not contain any hazardous, flammable, or combustible material (Refer to MSDS). Engulfment - the surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, or crushing. Entry - The action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that 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 Permit - The written or printed document that is provided by the employer to allow and control entry into a permit space.
PAGE 8 OF 9 Entry Supervisor - The person (such as the employer, foreman, or crew chief) responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required by this section. (This could be a Field Engineer, Foreman, Lead-man, or Hourly back-up, etc.) Immediately dangerous to life or health (IDLH) - any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual's ability to escape unaided from a permit space. NOTE: Some materials -- hydrogen fluoride gas and cadmium vapor, for example -- may produce immediate transient effects that, even if severe, may pass without medical attention, but are followed by sudden, possibly fatal collapse 12-72 hours after exposure. The victim "feels normal" from recovery from transient effects until collapse. Such materials in hazardous quantities are considered to be "immediately" dangerous to life or health. No entry permit shall be issued for confined spaces with an IDLH atmosphere. Isolation The process by which a permit space is removed from service and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tag out of all sources of energy; or blocking or disconnecting all mechanical linkages. Isolation Checklist - List of isolation points (Include bleeds verified as clear; add all blinds when installed and any spool pieces that have been removed for isolation) that must be approved by unit/shift supervision by signature or current EDM document. PPG Job Supervisor - The person (Unit, Maintenance, or Field Engineering) responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations as well as terminating entry as required by this section when utilizing contractors. Line Breaking - The intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure, or temperature capable of causing injury. Permit-Required Confined Space A confined space that has one or more of the following characteristics: Contains or has the potential to contain an atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to escape, injury, or acute illness from one or more of the following causes: o Presence of flammable gases, vapors, or mists. o Airborne combustible dust at a concentration that meets or exceeds its LEL. This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (1.5 meters) or less. o Atmospheric oxygen concentrations below 20.5 percent or above 21.5 percent. o Atmospheric concentrations of any substance that could result in employee exposure in excess of its permissible exposure limit. o Any other atmospheric condition that is immediately dangerous to life or health. Contains a material that has the potential to surround and effectively capture an entrant in a liquid or finely divided flowable solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, crushing, or smothering. Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor, which slopes downward and tapers to a smaller cross-section.
PAGE 9 OF 9 Contains any other recognized serious safety or health hazard such as, but not limited to, radiation, noise, electricity, extreme temperatures, or moving parts of machinery. Retrieval Systems - The equipment (including a retrieval line, chest or full-body harness, wristlets, if appropriate, and a lifting device or anchor) used for non-entry rescue of persons from permit spaces. Testing - The process by which the hazards that may confront entrants of a permit space are identified and evaluated. Testing includes specifying the tests that are to be performed in the permit space. NOTE: Testing enables employers both to devise and implement adequate control measures for the protection of authorized entrants and to determine if acceptable entry conditions are present immediately prior to, and during, entry. Ventilation - Natural or mechanical ventilation may be used to maintain acceptable atmospheric conditions. All welding, burning, cutting, blasting and spray painting within a permit required confined space shall be mechanically ventilated to control the creation of a hazardous atmosphere. Ventilation for potentially heavier than air gases should be from the top to the bottom of the space and ventilation for potentially lighter than air gases should be from the bottom to the top. Qualified Person - A person who by reason of training, education and experience is knowledgeable in the operations to be performed and is competent to judge the hazards involved. For the purpose of this procedure this person will be referred to as the "Equipment Owner Supervisor". 7. References 29 CFR 1910.146 Permit-Required Confined Spaces 29 CFR 1910.252 Welding, Cutting, and Brazing 29 CFR 1926.353 Ventilation and Protection in Welding, Cutting, and Heating CPL 2.100 Application of the Permit-Required Confined Spaces (PRCS) Standard NIOSH: Working in Confined Spaces; Publication 80-108 ANSI Z117.1-2003 Safety Requirements for Confined Spaces PPG Global EHS Requirements PPG Document # 4301-07-509 (Notification to Main Gate of Confined Space Entry) PPG Document # 4301-03-551 (ERP 6-18 Rescue Permit required Confined Spaces) PPG Document # 4301-06-488 (Legionella Control Program) PPG Document # 4301-06-491 (SP # 23 Fall Protection) PPG Document # 4301-06-343 (Plant Barricades) PPG Document # 4301-06-26 (Lifeline Confined Space) PPG Document # 4301-01-25 (PPE 20) Vertical Retrieval (tripod) Lake Charles Confined Space Matrix