Flammable Environments Guideline

GUIDE Flammable Environments Guideline 2014-0004

The Canadian Association of Petroleum Producers (CAPP) represents companies, large and small, that explore for, develop and produce natural gas and crude oil throughout Canada. CAPP s member companies produce about 90 per cent of Canada s natural gas and crude oil. CAPP's associate members provide a wide range of services that support the upstream crude oil and natural gas industry. Together CAPP's members and associate members are an important part of a national industry with revenues of about $120 billion a year. CAPP s mission, on behalf of the Canadian upstream oil and gas industry, is to advocate for and enable economic competitiveness and safe, environmentally and socially responsible performance. Disclaimer This publication was prepared for the Canadian Association of Petroleum Producers (CAPP) as a Guide for detecting flammable environments. While it is believed that the information contained herein is reliable under the conditions and subject to the limitations set out, CAPP and those who prepared this document do not guarantee its accuracy. The use of this guide and the information contained herein should be used in conjunction with the practices of the user's employer and will be at the user s sole risk, regardless of any fault or negligence of CAPP, its co-funders or those who prepared the guide. 2100, 350 7 Avenue S.W. Calgary, Alberta Canada T2P 3N9 Tel 403-267-1100 Fax 403-261-4622 1000, 275 Slater Street Ottawa, Ontario Canada K1P 5H9 Tel 613-288-2126 Fax 613-236-4280 403, 235 Water Street St. John s, Newfoundland and Labrador Canada A1C 1B6 Tel 709-724-4200 Fax 709-724-4225 310, 1321 Blanshard Street Victoria, British Columbia Canada V8W 0B5 Tel 778-410-5000 Fax 778-410-5001 www.capp.ca communication@capp.ca

Overview This document is a guide for CAPP members who are planning and supervising work where there is a need to minimize the hazards of a flammable environment. The content of this guide: Identifies regulatory requirements applicable in a flammable environment. Describes a process flowchart for determining action in a (possible) flammable work area. Raises awareness of associated hazards, which may minimize possible flammable exposure risks to workers and processes. Outlines a risk-based approach to ensure that all CAPP member worksites that have a potential of generating a flammable environment are identified and appropriate controls are implemented. Provides on-site work sheet tools (Appendix A) that can be copied and used as documentation forms to assess a worksite task for potential flammable exposure and identify appropriate controls. Page i

Contents 1 Project Scope... 1-1 2 Regulatory Compliance... 2-1 3 General Responsibilities... 3-1 3.1 Prime Contractor and/or Employer... 3-1 3.2 Area Management... 3-1 3.3 Frontline Supervisor... 3-1 4 Risk Controls... 4-1 4.1 Company... 4-1 4.2 Supervisor... 4-1 4.3 Worker... 4-1 5 Key Considerations... 5-1 5.1 Confined Space Tasks... 5-1 6 Determining the Requirements for Flammable Environments... 6-1 Appendix A Forms and Checklists Stop and Think Card for Flammable Environments Hazard Assessment for Flammable Environments Form Checklist for Flammable Environment Hazards Hazard Assessment for Flammable Environments Form (with completion instructions; print 8-1/2x11 or 11x17) December 2004 Page ii

1 Project Scope The following guideline provides CAPP employers and their supervisors with information to be considered when the work area has the potential of becoming a flammable environment. All levels of management must ensure as much as reasonably possible that CAPP Company personnel understand and can apply the necessary method(s) outlined in this guideline. The employer s supervisor serves as the principal person to provide technical information; if not available, the supervisor will designate someone at the worksite to manage the required practices. The site owner /Prime Contractor s supervisor is also the liaison with any contractors/employers on-site. The contractor must ensure their employees are trained on their own flammable detection and control programs and equipment. The task scope will identify flammable environment information requirements. The detail of subject training is the responsibility of the employers and must identify the appropriate level to ensure the worker is aware of the job flammable and explosive hazards and the controls, so that no harm will occur. Page 1-1

2 Regulatory Compliance All CAPP members have a duty to provide a safe worksite for those who may become exposed to a flammable environment. Supervisors are to ensure as far as reasonably and practicably possible that the task can safely be executed; workers have a general duty of protecting themselves and fellow workers. All provinces and territories have workplace legislation (Acts, Regulations and Codes) that direct employers to minimize risk to workers and that describe specific workplace acts and conditions that must be followed. These regulatory requirements prescribe a process for hazard assessments that include: The worksite assessment is to identify potentially flammable hazards before the work begins; the owner/employer must identify and inform the workers or contractor. The supervisor accountable for the work must conduct a task hazard assessment considering the impact site hazards may have on work. The Prime contractor is to identify the best means of communicating the work scope, to identify site conditions and to discuss potentially flammable hazards and the controls to the workers. The agreement at the onset of the job to a guideline of when to update the project s flammable hazard assessment: at periodic intervals, when new personal skills and/or equipment are introduced, the work scope changes or an emergency occurs. Regulations also prescribe a hierarchy for elimination and control of hazards: When a (potential) hazard exists, steps must be taken to eliminate it or control it. All reasonable and practical engineering controls must be the primary control. If the hazard cannot be eliminated or reasonably controlled through engineering, the employer must use, Administration controls, such as: ventilating, dispersing, displacing, work procedures, or through the use of specialists on that type of work. Protective equipment (the last line of defense for personal exposure), such as: wearing protective clothing, atmospheric personal monitors, early warning detection devices, or Combination of both, administration controls and protective equipment. Part 10 of the Alberta OH&S Code specifically addresses fire and explosion hazards. January 2003, Alberta Human Resources and Employment, Workplace Health and Safety issued a Hazardous Location letter (HL001 January 2004) to industry regarding the hazards of not adequately testing the personal monitor prior to entering a potentially hazardous area. The notice specifically reminds owners to follow manufacturer s recommendations and be aware of the CSA Standards. Page 2-1

The Canadian Standards Association s CSA Standard C22.2 No. 152-M1984, specifically Clause 5.3.1(K) states that companies using personal flammable atmospheric gas detectors must be bump tested (exposed to a calibrated gas) at the start of the shift. Employers should be familiar with Industry Recommended Practices and have a copy of the equipment manufacturers recommendations. It is this information that must be available and shared with the users. Employers should be competent in the business activities and aware of applicable resources that pertain to their own company equipment and tasks that they expect their employees and contractors to do. Page 2-2

3 General Responsibilities 3.1 Prime Contractor and/or Employer General Manager, Senior Executives, President Ensure adequate engineering controls are in place to contain flammable gasses. Monitor the business tasks and ensure adequate equipment to protect their workers doing those tasks. 3.2 Area Management Superintendent, Coordinator, Consultant, Manager Ensure a hazard assessment is conducted for flammable environments. Confirm employees are competent in the assigned tasks or are working under direct supervision. Ensure the protective equipment (e.g. gas detectors/monitors, breathing air equipment) is available and workers are competent on their use. 3.3 Frontline Supervisor First Line Supervisor, Skilled worker Ensure self and workers under their supervision understand the flammable hazard assessment and control measures and are able to implement the scope of work and hazard controls. Ensure their workers are trained on required protective equipment (Gas detectors, Breathing air supply types). Employers must ensure gas detection equipment is only used by competent workers. Risk increases when specialized equipment, like gas detectors, are used by workers who may not be trained on their use. It is, therefore, recommended that all employers, prior to the start of work, conduct a hazard assessment to identify the personnel involved in the work and ensure competency on the equipment provided. Page 3-1

4 Risk Controls Managing risks start at the owner company level and migrate to the worksite. The following is a suggested list of items to consider in managing the work: 4.1 Company Have a system in place for containment of flammable products during normal operations. Have a system in place for maintenance of the containment. Select workers and contractors who can do the work safely. 4.2 Supervisor Be familiar with the company s flammable environment control and detection programs. Ensure workers are competent or working under direct supervision of a competent worker. Conduct a hazard assessment specifically for flammable environments and document the controls that will be used. Communicate the hazards and controls to all workers on the site and get agreement on the processes, preferably by signing off on the hazard assessment. 4.3 Worker Confirm that adequate flammable / explosive environment hazard controls are in place by testing the atmosphere, reviewing the hazard assessment and implementing the mitigating actions from the assessment. Page 4

5 Key Considerations 5.1 Confined Space Tasks Companies require their own Code of Practice for entry into confined spaces. This work is very specialized and the requirements for detection equipment, written procedures, checklists, safety watch and training exceed the requirements for basic gas detection in a non-confined space scenario. This guide is not intended to meet the regulatory or safety requirements for confined space entry. Page 5

6 Determining the Requirements for Flammable Environments Figure 6-1 outlines the steps for determining adequate processes in the event of a potential flammable environment. Each step identifies the overall process considerations to ensure a worksite does not contain an unacceptable flammable atmosphere and that responsibilities are appropriately assigned for mitigating actions. 1) Define the Work Determine potential of a flammability condition in the scope of the work 2) Identify Flammability Risks Determine inherent flammable and explosive levels of the worksite and that may be introduced durinng othe work 6a) Assess changes Re-define the scope of the work with the new condition levels Yes 3) Define Control Measures Specify a control measure for each flammable source hazard 4) Select the workers Choose workers who can implement the control measures 6) Execute the Work Do the work using the control measures established. Has the scope of the work or conditions changed? 5) Communicate the work plan Ensure the workers on-site understand the flammability hazards and can implement the control measures No 7) Complete the Work Identify any residual flammable hazards that remain Figure 6-1: Process Flowchart Possible Flammable Environment Page 6-1

1) Define the Work that is to be Done: Every job must start with a clear definition of the scope and type of work to be done. Protective equipment and detection equipment requirements cannot be determined unless the nature of the work is first described. Defining the work must include: Who is the owner s representative for the site? Who is the contractor's representative? Who will be conducting the work? What equipment will be used? Is the work 'hot work' as defined by OH&S? Does the work involve breaking containment or is the work intrusive (i.e., opening systems that contain or have contained hydrocarbons)? 2) Identify Hazards and Risk of the work: The defined task specifically related to potential flammable and explosive hazards must be identified. The site supervisor (usually the owner s representative) has the responsibility to identify the potential flammable hazards inherent to the site. The task supervisor has the responsibility of identifying the hazards associated with the work they will be doing. The process of identifying the hazards is best done on the work site and the work sites should be physically inspected to determine the nature of the hazards. Conducting a hazard assessment will: Identify flammable products in the facility. Identify concentrations of flammable gas (methane, propane, etc) present. Identify if the work will release any flammable products from the contained systems. Assess the specific work site tasks as well as the overall work site tasks to determine the impact on each other. Quantify any levels of flammable and explosive gases in the work place. Identify other hazardous substances that may be mixed with the flammable gas (i.e. H 2 S, benzene). 3) Define Control Measures: The principles of a good hazard mitigation plan align each of the identified hazards with an appropriate control measure. Defining Control Measures must: Identify engineered processes for keeping gases contained (isolated by Lock out/ Tag out, Double Block and Bleed, Blinding, etc). Page 6-2

Identify ventilation methods to keep flammable vapours below 10% of the Lower Explosive Limit as well as below the Occupational Exposure Limits (OEL). Identify the L.E.L. up to which work can continue while wearing breathing apparatus. Identify the specific gases that could enter the immediate work environment. Specify the detection equipment that will be used for measuring the identified gases in the immediate work environment (e.g., fixed or portable monitors, single head LEL or multiple head detector). Identify type of personal protective equipment required (fire retardant coveralls, breathing air pack). Establish action plans for changing conditions (detection of gas, alarms, scope of work changes). Define who will implement each of the control methods. Define and review emergency response plans. 4) Select the workers to do the work: Once the scope of the work is defined and the flammable hazards and control measures have been identified, the supervisor selects workers who are competent in working with those hazards and control methods. These workers can be employees of the owner or competent contractors who are familiar with the hazards of the work. If the control methods require the use of gas monitoring, then only workers who are competent on the use of that equipment can be used. Considerations for selecting the workers must include: Ensuring the workers are skilled in the scope of work. Defining who has the responsibility of implementing each of the control measures. Defining who will be using the gas detection equipment on the site. Ensuring the workers are competent in the use of the gas detection equipment that has been selected. 5) Communication and Hand-over of the work: A method is required to communicate the first four steps of this process to the workers who will be executing the tasks. The method needs enough structure to ensure that the important information around the scope of work, the hazards and the risk and control measures gets communicated directly to the workers involved. The communication and hand-over must include: A safe work permit or safe work agreement system. A reference document for the identified flammable hazards and control measures. ( a Job Safety Analysis or other hazard assessment processes). Page 6-3

An acknowledgement of the flammable hazards and an understanding of control measures. A review of the Emergency Response Plan. 6) Execute the work: The work now takes place with full knowledge of the scope, the identification of potential flammable hazards, the control measures and the responsibilities. The work execution phase must include: A verification that all flammable hazards are controlled. A verification that the control measures are working. A method for identifying changes to the flammable hazards and risks. A process for identifying scope changes and linking the scope changes back to the structure of defining the work and re-defining the risks. Ongoing monitoring of the work site consistent with the control measures. Ongoing monitoring of the work and the workers to ensure the work progresses consistent with the plan. A process for stopping work if conditions or actions vary from the plan. 7) Completion and Hand-back: The end of the job needs to be defined and any residual flammable environment hazards from the work need to be identified. The completion and hand-back process must include an inspection of the work site to: Ensure that no residual leaks or emissions remain after the work. Confirm all safeguards (fixed detection, caps, plugs, gates) are back into the secure position. Ensure the close-out (either a meeting or an update of on the documentation) captures lessons learned, new hazards identified and improvements to that work process. Page 6-4

Appendix A Forms and Checklists Stop and Think Card for Flammable Environments Hazard Assessment for Flammable Environments Form Checklist for Flammable Environment Hazards Hazard Assessment for Flammable Environments Form (with completion instructions; print 8-1/2x11 or 11x17) A-i

The Flammable Environment Task Set Up Do I know what type of gases are in this facility or equipment? Will the gases remain within the system while I am working on it? Are there other crews, work or processes that could release of the gas? Detecting the Gases If the gas is released, how will I know? Do I have the appropriate equipment to detect this gas? Is it working? Do I know how to use this equipment? Have I ensured that a leak will not be ignited should it occur? Identifying Changes What could change that would impact my work plan? Will my work release gases that could impact other crews or work? Do I still have the gases contained as my work progresses? Copies of the above card are available from CAPP Publications (email: publications@capp.ca) Page A-ii

Hazard Assessment for Flammable Environments Work activity (job): Work team: Work Location: Date: Hazard Assessment prepared by: Critical Questions: What is in this facility/equipment we will be working on? Flammable Liquids exposure been addressed? Has the worst case been discussed? Has the Stop and Think card been discussed? Flammable Gases Has the potential for a leak or List Job Steps that could release Flammables Existing/Potential Hazards from the Flammables Ways to Eliminate or Reduce Potential Hazards Special Safety Equipment Required for Control, Detection and Protection from a Flammable Environment Gas Detection What Type? Flammable (LEL) H2S Both MSDS Other (specify) Who will be supplying the detection equipment? Has the equipment been function tested? Who will be using the detection equipment? Is this person trained on this detector? Page A-3

Other Equipment: Wind Indicator Fire Retardant Clothing Fire Extinguishers Ventilation Equipment NOTE: These are in addition to the Critical Questions listed on the front of the Hazard Assessment Questions to Consider when Preparing a Hazard Assessment for Flammable Environments Are you qualified to prepare the hazard assessment for this work? Is the hazard assessment being prepared at the work site? Do you need a detailed work procedure to control the flammable environment for this job? Are company personnel familiar with the operations and flammable products in this work area reviewing the hazard assessment? Are you using your Safety Management System to help develop the assessment? Will this hazard assessment be reviewed with all the workers who will be involved in the work? Do we have someone qualified to use the detection equipment we are providing? If the hazard assessment is not prepared on the work site, will the workers on the site inspect the work site and upgrade the assessment before work begins? Do you have all the necessary safe work agreements/permits to do the work? Have you done this job before? Is now the right time to be doing the work? Are you communicating with others who may be affected by the work or by the flammable environments that may be created? Are we able to function test our detection equipment? Do all the workers understand their roles in controlling and responding to flammable environments on this work site? Other: Sources of Flammable Gases and Liquids to Consider Fittings Wellheads Poor ventilation Flow lines Valves Fuel Tanks Spilled Liquids Tank Vapours Venting Operations Poor air circulation Drains Contaminated Soil Ignition Sources to Consider Electrical Equipment Motors/Exhausts Static Electricity Hot Surfaces Vehicles Non-Intrinsically Safe Equipment Cathodic Protection Lightening Lights Hand Tools Pyrophorics Non Explosion-proof equipment Page A-4

Describe the specific job. Identify the company and crew that will conduct the work. Be specific. Use the site owner s name and identify the location. Date the hazard assessment was completed. List the names of everyone who participated in the assessment. Describe the product. Provide an MSDS if required. Use descriptions such as methane, propane, light crude, heavy crude, etc. Identify steps in the job where flammables will be released, could be released, or where the nature of the work could damage equipment and cause a release. Hazard Assessment for Flammable Environments Work Activity (job): Work Team: Work Location: Date: Hazard Assessment prepared by: Critical Questions: What is in this facility/equipment we will be working on? Flammable Liquids Flammable Gases Has the worst case been discussed? Has the Stop and Think card been discussed? Has the potential for a leak or exposure been addressed? List Job Steps that could release Flammables Existing/Potential Hazards from the Flammables Ways to Eliminate or Reduce Potential Hazards Special Safety Equipment Required for Control, Detection and Protection from a Flammable Environment Gas Detection What Type? Flammable (LEL) H 2 S Both MSDS Other (specify) Who will be supplying the detection equipment? Has the equipment been function tested? Yes No Who will be using the detection equipment? Is this person trained on this detector? Yes No Other Equipment: Wind Indicator Fire Retardant Clothing Fire Extinguishers Ventilation Equipment 1240 Describe the specific flammable hazard. Describe how release of a flammable will be prevented. How a release will be detected if it occurs and what will be the response. Worker s name Company name Where other is used, state reasons.