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1. PURPOSE
This policy establishes requirements for inert confined space entry for the NROC Site.
This policy will be used in addition to the Site’s Confined Space Procedure (PA-020-
0004). An Inert Entry is required when removing or loading catalyst, packing or
desiccants that are pyrophoric in nature and could create a fire when coming in contact
with air.
2. DEFINITIONS
2. DEFINITIONS cont’d
NOTE:
For air contaminants for which OSHA has not determined a dose or permissible exposure
limit, other sources of information; such as, Material Safety Data Sheets, ACGIH TLVs,
published information, and internal documents may provide guidance in establishing
acceptable atmospheric conditions.
2. DEFINITIONS cont’d
3. SCOPE
4. PROCEDURE
4.1.1. Conduct a detailed review of the training program during the initial review
of any Inert Entry Contractor considered for addition to the Approved
Contractor List. This review should include quality of training materials,
review of training records, instructor qualifications, and experience
requirements in each position. It is critical that specific personnel who will
carry out the inert entry have adequate training and experience.
4.1.2. All contractors that perform Inert Entry work must have their Safety
Program reviewed, including Inert Entry and Rescue Procedures, against
the key requirements of this document.
4.1.3. Review fit test records to ensure that personnel working in breathing air are
routinely examined for medical fitness as required by OSHA 29 CFR
1910.134.
4.1.4. Review inspection and test records for all breathing air equipment, Life
Support Systems, emergency rescue equipment and gas testing
equipment to ensure it is routinely inspected and tested.
4. PROCEDURE cont’d
Company Management
Although a qualified contractor will perform the inert entry, BASF employees must
be involved in the operation to provide the contractor with the proper facility
knowledge, job expectations and accountability to complete the job safely.
4.3.1. Contractors written site safety and emergency/rescue plan will be reviewed
by Shift Supervisor and Site EHS personnel before the start of work.
4. PROCEDURE cont’d
4.3.2. Prior to inert entry, the Area Maintenance Coordinator will coordinate a
meeting to discuss the contractor’s written plan for performing work under
inert conditions. Meeting attendees shall include:
Shift Supervisor
Contractor Safety Representative
EHS Representative
Contractor Foreman
Area Operations Coordinator
Area Operations Technician
4.3.4. Air Supply must be Certified Grade D quality breathing air. A quality
control check will be made by On-Site Safety Store personnel as the
bottles are brought to the Site. The bottles will be individually tested and
tagged.
4.3.5. Blended or synthetic air will NOT be used for supplied breathing air used
by employees or contractors.
Contractor
Written Documentation
Contractor must provide to BASF representative written documentation prior to
commencement of work supporting qualifications for working in an inert
environment. The minimum documentation required should include:
4.3.6. Employee service and current training records for all crew members.
4. PROCEDURE cont’d
4. PROCEDURE cont’d
4. PROCEDURE cont’d
4. PROCEDURE cont’d
4.3.16. Rescue/Evacuation
Adequate emergency rescue facilities should be immediately available
at the vessel manway and the contractors should be trained in its use.
This should include:
Hoisting device and wire lifeline to extract person from the inside of
the confined space.
Persons working inside the vessel should wear a harness
(Shoulder D Ring Type), which enables the person to be lifted out
of the vessel in a vertical position.
A pre-planned means of lowering the person to the ground. (stokes
basket)
A radio or other means of summoning assistance.
The attendant at the vessel must wear standard inert entry
equipment so that in an emergency they can enter the vessel to
assist the injured person. A spare set of standard inert entry
equipment must be available at the vessel manway so that another
technician can replace the safety standby.
Trained personnel to provide emergency first aid and
cardiopulmonary resuscitation (CPR)
4. PROCEDURE cont’d
4.3.18. Process/Operations
There must be a primary (truck/trailer) supply and secondary nitrogen
(plant N2) supply to the vessel. The primary trailer supplying the
nitrogen must be backed up by a second trailer that is staged on site.
In the event that a nitrogen trailer runs empty, operations will switch
over to the secondary plant nitrogen system until a trailer swap is
accomplished. O2 and temperatures should be watched carefully
during this time. Ideally there will be two nitrogen trailers on site at all
times with a third trailer being in transport between the Site and the
Nitrogen fill facility.
Due to the potential for some catalyst to develop crust, planning the
introduction of nitrogen supply must address methods to eliminate
the potential for build-up of pressure below this crust.
4. PROCEDURE cont’d
Permit issuers must test all areas around the openings to determine
boundaries of regulated areas. The boundaries will be barricaded
to ensure non-entry personnel do not enter oxygen deficient
environments.
Open manways must be secured to prevent fall hazards.
Any deviations from the Confined Space Permit or Inert Entry
Procedure must be documented and signed off by appropriate
personnel.
4.4.2. PPE
The PPE hazard assessment completed during the planning phase should
clearly identify the PPE required for all task being performed during each
specific inert entry operation. Contractor supervision must enforce the
implementation of the requirements identified by the Safe Work Permit.
BASF will also audit the use of required PPE.
4. PROCEDURE cont’d
4. PROCEDURE cont’d
Contractor
In order to maintain a safe environment, the contractor should maintain a
periodic log or checklist of continuous monitoring. BASF personnel will
periodically audit these readings. The checklist or log must included:
Vessel Temperature
LEL
Oxygen Concentration
Air Supply (Primary & Secondary) Checks
Communication Checks
Operations
Area operations technician will be responsible for maintaining a safe
working environment. Responsibilities include:
Audit of contractors to ensure ongoing monitoring is taking place
Contact will BASF board technicians to ensure temperatures and
other variables are maintaining
Performing LEL/O2 readings determined by permit requirements
Personal presence in the area of Inert Entry
Issuance of all permits required for work being performed
Ensuring adequate nitrogen flow is maintained
Informing contractors of any emergency situations
Ensuring company LEL meters are checked by “bump testing” at
least once per shift
4. PROCEDURE cont’d
5. RESPONSIBILITIES
6. RELATED DOCUMENTS