Confined Space Entry

Confined Space Entry
September 2004
Policy and strategic objectives

Organisation, responsibilities resources, standards, documents
Hazards and Effects Management
Planning and procedures
Corrective action
Implementation
Monitoring
Audit
Corrective action and improvement
Management review
Corrective action and improvement
Health, Safety and Environment
HSE
Shell Health, Safety and Environment Panel
Confined Space Entry
The companies belonging to the Royal Dutch/Shell Group of companies are separate and distinct entities, but in this document the collective expressions Shell and Group are sometimes used for convenience in contexts where reference is made to the companies of the Royal Dutch/Shell Group in general. These expressions are also used where no useful purpose is served by identifying the particular company or companies. This document is prepared by Shell Internationale Petroleum Maatschappij B.V. (SIPM) as a service under arrangements in existence with companies of the Royal Dutch/Shell Group; it is issued for the guidance of these companies and they may wish to consider using it in their operations. Other interested parties may receive a copy of this document for their information. SIPM is not aware of any inaccuracy or omission from this document and no responsibility is accepted by SIPM or by any person or company concerned with furnishing information or data used in this document for the accuracy of any information or advice given in the document or for any omission from the document or for any consequences whatsoever resulting directly or indirectly from compliance with or adoption of guidance controlled in the document even if caused by a failure to exercise reasonable care.
SHELL HEALTH, SAFETY AND ENVIRONMENT COMMITTEE The copyright of this document is vested in Shell Internationale Petroleum Maatschappij B.V., The Hague, The Netherlands. All rights reserved. September 2004
Confined Space Entry, Issue 2.0, September 2004
Confined Space Entry, Issue 2.0, September 2004 d
Document History
Date April 1992 September 2004 Issue 1.0 2.0 Reason for change First Issue Second Issue Author Approval Signature
OGCH/1
The printed version of this document is the controlled version. It is also available on the PXE Website. Superseded issues of this document should be destroyed.
Table of Contents
Table of Contents
1 Purpose 1.1 Definition Scope and Application Group Standards and Requirements Management System 4.1 Objectives 4.2 Responsibilities and Competence 4.3 Planning, Procedures and HEMP 4.4 Rescue Plans 4.5 Monitoring and Audit 4.6 Management Review Confined Space Hazards 5.1 Oxygen Deficiency 5.2 Oxygen Enrichment 5.3 Fire and Explosion 5.4 Toxic Hazards 5.5 Corrosive Hazards 5.6 Physical Hazards 5.7 Unsafe Conditions 5.8 Psychological Issues Controls that Apply to All Confined Space Entries 6.1 Permit to Work 6.2 Mechanical Isolation 6.3 Electrical/Hydraulic Lock-out and Tag-out 6.4 Clearance of Process Materials 6.5 Ventilation 6.6 Testing and Monitoring 6.7 Control of Ignition Sources 6.8 Control of Radiation Sources 6.9 Lighting and Electrical Equipment and Tools 6.10 Internal Combustion Engines and Gas Cylinders 6.11 Personal Protective Equipment (PPE) 6.12 Access and Escape 6.13 Attendants 6.14 Fitness to Work 1 1 2 3 4 4 4 5 5 7 8 9 9 10 10 11 12 13 13 13 15 15 15 16 16 16 17 18 19 19 19 20 20 20 21
2 3 4
Table of Contents
Entry Criteria and Specific Controls 7.1 Normal Confined Space Entry Without Breathing Apparatus 7.2 Exceptional Confined Space Entry With Supplied Air Breathing Apparatus Inert Gas Confined Space Entry for Catalyst Handling 8.1 Hazards 8.2 Equipment and Resources 8.3 Managing Specialist Contractors References Glossary
22 23 23 25 25 27 29 30 31 33 36 38
9 10
Appendix 1 Responsibilities Of Key Personnel Appendix 2 Competence Profiles Of Key Personnel Appendix 3 Rescue Plans
Gas Freeing and Cleaning of Storage Tanks, Issue 3.0, February 2003
1 Purpose and Scope
Purpose and Scope

The objective of this guide is to provide business units (BUs) with the recommended practices for controlling health, safety and environmental hazards during confined space entry (CSE). It sets out recommendations within the framework of the Group HSE-MS, and introduces a risk based approach to the planning and execution of work. By applying this guidance BUs across all Shell businesses and sizes of operation should achieve a consistently high level of control of activities involving CSE.
1.1
Definition
A confined space is a fully or partially enclosed space where there is a risk of serious injury from hazardous substances or conditions within the confined space. Refer to the Glossary in Section 10 of this guide for an explanation of the concepts of an enclosed space and of hazardous substances or conditions. A confined space entry (CSE) means not only complete body entry, but also inserting a head into man way openings, hatches, pipe ends etc.
2 Scope and Application
Scope and Application

Section 3.0 of this guide sets out the Group Standards and Group Requirements for CSE. Section 4.0 provides guidance on Management System aspects. Section 4.3 describes the role of procedures and HEMP in planning and implementation of CSE. Sections 5.0, 6.0 and 7.0 provide guidance on the hazards and controls that should be considered in the HEMP. This guide should be used in conjunction with other Shell Group, Shell Business and Industry guides, which are referenced in the text and in Section 9.0. Section 8.0 describes the specific hazards and controls for handling of catalysts in inert gas confined spaces. It relates to activities conducted only by specialist catalyst handling contractors and should be read separately from the other sections of this guide. This guide replaces Guidelines for Entry into Confined Spaces (1992). The CSE atmosphere criteria in this guide supersede those in the guide Gas Freeing and Cleaning of Storage Tanks (2003). This guide is intended for use by Group BUs when developing or reviewing their procedures and practices for CSE.
3 Group Standards and Requirements
Group Standards and Requirements

This section sets out any Group Standards that underpin the guidance in this document, plus the Group Requirements that have been drawn out of the body of the guide. Group Standards have been approved by the leadership of the Shell Businesses and subsequently endorsed by the CMD. These standards are mandatory for all Businesses and Business Units. Group Requirements are expected to be in place and will be checked as part of the HSE MS audit process. These Group Requirements are described in more detail in the body of the guide using the following protocol to distinguish mandatory Standards and Group Requirements from recommended guidance: Shall - Indicates mandatory; requires justification to deviate Should - Indicates recommended; to be considered None of the Group HSE Standards are directed specifically at CSE, but the following Group Requirements apply: The Hazard and Effects Management Process (HEMP) shall be applied for confined space entry (CSE) activities. The HEMP shall include the following steps: - Identification of the hazards; - Assessment of the risks using the Risk Assessment Matrix (RAM); - Detailed analysis of the hazards, e.g. by job hazard analysis (JHA), in case of activities assessed as high or medium risk on the RAM; - Description of the necessary controls and recovery measures. If a generic HEMP exercise and the guidance in this document have been incorporated into CSE procedures, the job specific HEMP shall focus on identifying the controls and recovery measures for the particular CSE and location; The HEMP shall demonstrate that alternatives to entering the space have been considered and that all reasonably practicable steps have been taken to eliminate asphyxiant, flammable, toxic and other hazards; The CSE criteria for oxygen, toxic and flammable levels and for breathing apparatus in Section 7.0 of this document are mandatory; A rescue plan shall be prepared and implemented for every CSE; Every CSE shall be authorised and controlled by a permit to work.
4 Management System
4
4.1
Management System
Objectives
Every effort should be made to minimise the need for CSE, which is an inherently hazardous activity, by methods such as the following: Designing out the need for entry by flooding the legs of offshore production platforms; Maximising the extent of cleaning of tanks and vessels whilst they are still in operation; Applying robots and mechanical devices instead of people for cleaning tanks; Applying on-line inspection methods such as ultrasonics; Minimising below ground level pipe trenches and process equipment in pits. Where CSE cannot be avoided, for example, for cleaning, inspection and maintenance of the equipment, every effort should be made to eliminate the asphyxiant, flammable and toxic hazards by positive isolation, thorough cleaning, gas purging and ventilation of the space. In the design of new facilities consideration should be given to the need for persons to enter into process equipment and to facilitate the rescue of persons from the space. Some examples are: Providing sufficient man ways of adequate size on process vessels and columns to allow entry of persons and materials and ventilation of the space; Fitting tray man ways in distillation columns directly above each other to facilitate movement and rescue.
4.2
Responsibilities and Competence

Key persons involved in CSE activities are: Operations supervisor (Permit Issuer), who is responsible for making sure that the confined space is safe for entry, and that the supervisor in charge of the work and the attendant are fully familiar with the hazards, controls and recovery measures; Supervisor in charge of the work (Permit Holder), who is responsible for making sure that the workers comply with the controls specified on the permit, and for providing means of rescuing persons from the space in case of an emergency; Standby (Attendant), who is responsible for maintaining communications between all parties and raising the alarm in case of an emergency inside the space; Persons inside the confined space, who are responsible for using all the tools and PPE supplied and complying with the specified controls. Typical responsibilities for these key personnel are detailed in Appendix 1. CSE is considered to be a HSE Critical Activity. A structured competence assurance process, defined within the scope of the BU HSE-MS, should therefore be applied to the key persons involved in CSE activities. Refer to Appendix 2 for more details.
4 Management System
4.3
Planning, Procedures and HEMP

CSE is one activity in a complex sequence, which typically includes shutdown of the unit, clearance of process materials (draining, venting, flushing, purging), positive isolation, ventilating, gas testing, entry for cleaning and inspection, maintenance, de-isolation, pressure and leak testing, oxygen freeing and finally starting up the unit. The activities should be planned in detail and in time to make the necessary operational and engineering preparations. Typically, CSE activities will be planned by the Operations and Maintenance organisations, and contractors who will be doing the work. HSE requirements should be built into this planning process and into implementation of the plan by means of the Hazard and Effects Management Process (HEMP) having the following steps: Identify the hazards involved in each activity in the sequence. Techniques such as HAZID can be applied. Refer to EP 95-0312 for more details. Section 5.0 has more detail of typical confined space hazards; Assess the risks associated with each activity, applying the RAM; Analyse activities that are assessed as High or Medium on the RAM in more detail, using a method such as JHA to identify controls needed in addition to the standard confined space procedures and work instructions. For CSE work the JHA should address: - Health hazards, based on generic or job specific HRA, in addition to the more obvious safety hazards; - Specific monitoring requirements, e.g. continuous testing of the atmosphere in the confined space, when the analysis identifies the possibility that conditions could change during the work; - Escape requirements and a job specific rescue plan. Implement the controls and rescue plan when carrying out the activities. Use the JHA at kick-off meetings for the work and in daily worker team meetings. When the BU or site has a CSE procedure that is based on a generic JHA and the guidance in this document, the HEMP may be limited to checking that the controls and recovery measures are fully applicable to the planned work and location. BUs should develop and implement CSE procedures based on the standards and guidance in this document and the HEMP described in the previous paragraph. The procedures should explain what constitutes a confined space, including the less obvious excavations, drains and pits. There should be a clear link between these procedures and the permit to work procedures.
4.4
Rescue Plans
Rescue plans are an integral part of the planning of confined space work. A rescue plan shall be prepared as part of the JHA for the specific CSE, and it should take account of any legal requirements. When a generic rescue plan is available it shall be checked for applicability to the CSE being planned. The BU or Site emergency services personnel, especially those with experience of confined space rescue, should be involved with Operations and Engineering personnel in developing the rescue plan.
4 Management System
4 Management System
The following key points should be considered in the development and implementation of confined space rescue plans: Entry of persons into a confined space should not be allowed until a plan for rescue of incapacitated persons from any part of the space has been developed, resourced and rehearsed. The minimum rehearsal is to talk through the plan and individual responsibilities, with nominated rescuers present, as part of the kick-off meeting at the work-site; If retrieval systems are needed, e.g. lifelines, tripod winch and full body harness, these should either be set-up/in use or available in the immediate work area; Rescue personnel should not put themselves at risk when attempting to rescue persons from a confined space. There have been many cases where rescuers have succumbed to the same conditions as the persons they were trying to rescue; The attendant should not attempt a rescue. Some questions that should be asked and the factors that should be taken into account when developing rescue plans are set out in Appendix 3.
4.5
Monitoring and Audit

The Operations Supervisor and/or HSE personnel should monitor work under permit control on a daily basis, including spot checks of worksites, permits and supporting documents and rescue arrangements. In-depth inspections should be carried out at a predetermined frequency by persons independent of the unit being inspected, e.g. by line personnel from another unit or department or by HSE advisers. A checklist such as the one in Appendix 6 of Permit to Work, HSE Advisers Panel (2003) can be used. It is recommended to audit the effectiveness of control of CSE activities across the whole installation or site at least every two years, or more frequently if indicated by incidents, routine monitoring, or local regulations. Audits should be carried out by qualified technical auditors who are experienced in CSE activities and are independent of the installation or site being audited. As CSE is inherently hazardous it is important to capture the experiences and learning from incidents that occur during confined space work. It is recommended to highlight CSE as a focus area of incident and near miss reporting procedures.
4 Management System
4.6
Management Review
Line Management should periodically review the effectiveness of the CSE procedures and practices, and where necessary they should revise the procedures. Factors to be taken into account include: Changes in legislation, Industry and Group guidelines; Review of incident reports; Inspection and audit findings; Feedback from those involved in CSE activities. It would be appropriate to review the standards and relevance of guidance in this document at the same time, and provide feedback to the business and Corporate HSE advisers.
5 Confined Space Hazards
Confined Space Hazards

This section describes the hazards that are commonly found in confined spaces. They should be taken into account when assessing the risks and establishing the controls for CSE activities.
5.1
Oxygen Deficiency
The normal, naturally occurring atmospheric concentration of oxygen is 20.8% vol. at sea level. Atmospheres containing less than 20% vol. oxygen are considered to be oxygen-deficient. The oxygen content of air reduces as altitude increases, therefore locations at more than 1000 metres above sea level should make an adjustment to the criteria in this guide. Oxygen deficiency in an atmosphere can result in asphyxiation. A relatively small reduction in the oxygen level can lead to impaired mental ability and can provoke a feeling of euphoria or well being leading to an overoptimistic judgment of the situation. The effects generally occur without alerting the senses. Loss of consciousness can occur without warning. This can happen even in circumstances where only a persons head is inside a confined space. Very low oxygen concentrations, below 10%, can lead to unconsciousness and death. Inhaling an atmosphere with no oxygen results in instant death. There is no panic or discomfort; death is swift and silent. Oxygen deficiency can result from:
Displacement of air from low points in a confined space by heavier gases such as hydrocarbons or
carbon dioxide;
Purging of the confined space with an inert gas to remove flammable or toxic gases, fumes,
vapours or aerosols;
Naturally occurring biological processes that consume oxygen, which can occur in sewers,
storage tanks, production platform legs, storm water drains, wells etc.; Leaving a vessel completely closed for some time, since the process of rust formation on the inside surface consumes oxygen. Newly fabricated or shot blasted carbon steel vessels are especially vulnerable to rusting; Increased levels of carbon dioxide evolving from limestone chippings associated with drainage operations; Burning and welding, which consume oxygen; Displacement of air during pipe freezing with liquid nitrogen; Gradual depletion of oxygen as workers breathe in confined spaces and where provision of replacement air is inadequate.
Any reduction in the oxygen level from atmospheric concentration shall be investigated, the risks assessed and appropriate measures taken. Entry into confined spaces containing 16 to 20% vol. oxygen shall be allowed only by exception, when the source of oxygen deficiency is understood and it is not practical to ventilate the confined space to atmospheric oxygen level.
Atmospheres containing less than 16% vol. oxygen shall be treated in the same way as toxic atmospheres that are Immediately Dangerous to Life and Health (IDLH). Entry into confined spaces containing less than 16% vol. oxygen shall not be allowed, except under inert gas entry conditions as described in Section 8.0.
5.2
Oxygen Enrichment
The normal, naturally occurring atmospheric concentration of oxygen is 20.8% at sea level. Atmospheres containing more than 21.5 % vol. oxygen should be treated as oxygen enriched. Oxygen enrichment will significantly increase flammability of clothing, grease and other combustible materials. Oxygen enrichment can result from:
Leaks from oxygen containing equipment such as gas cylinders, valves, hoses and welding torches; Inadvertent use of oxygen instead of air for ventilation or breathing air; Deliberate addition of oxygen to increase the level of an oxygen deficient atmosphere.
Any increase in the oxygen level above normal during CSE activities should be investigated, the risks assessed and appropriate measures taken. The most common oxygen containing equipment is that used in gas cutting operations. Cylinders, gas hoses, valves and welding torches should be handled with care and should be daily inspected for damage. Gas cylinders should not be taken into confined spaces. All cutting and welding equipment should be removed from confined spaces during breaks and at the end of the working day.
5.3
Fire and Explosion

Fires and explosions can result from accumulations of flammable vapours, fumes or dust in the presence of a source of ignition. Mixtures of flammable vapours and air will only ignite if the hydro carbon to air ratio is between the Lower Flammable Limit (LFL) and the Upper Flammable Limit (UFL). Flammable vapours or fumes typically result from: Materials previously processed or stored in the vessel or tank; Sludge or other deposits disturbed during cleaning; Material left under scale, even after cleaning; Material leaking through the tank floors; Material leaking from behind vessel linings (rubber, lead, brick, refractory etc.) or from vessel fittings such as tank floating roof pontoons and legs, instrument connections or pipes; Materials leaking from flanges or vents on process pipes running through the confined space, e.g. production flow lines in platform legs or process tubes in a furnace combustion chamber;
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Vapour entering the confined space from nearby process plant that has not been effectively
isolated or from nearby work that is not well controlled; Solvents brought into the space for cleaning, painting, dye penetration tests or in adhesives; Gases brought into the space for welding or gas cutting, including leakage from cylinders, valves and hoses; Contaminated firewater/process water used to wash the confined space and introduced by hoses; Vapour or fumes that build up in sewers, manholes, contaminated ground or excavations.
A source of ignition can be any heat source having enough energy to ignite a flammable vapour air mixture, or to raise the temperature above the auto-ignition temperature. Possible ignition sources include: Open flames and sparks resulting from welding, gas cutting and grinding; Sparks or arcs produced by electrical equipment, lightning and electrostatic charges; Hot pipes or exhausts that can raise the flammable mixture above the auto-ignition temperature; Heat of friction during drilling, sawing or other cutting activities; Pyrophoric materials, e.g. iron sulphide in scale; Thermite reactions from aluminium or other alloy tools striking against rusted iron or steel; Any highly reactive material capable of producing sufficient heat for combustion, for example: - Strong oxidising substances, such as hydrogen peroxide used in waste treatment facilities; - Chemicals that undergo self-accelerating exothermic reactions when a critical temperature is reached, such as ethylene oxide. The recommended approach to controlling fire and explosion hazards in confined spaces is to eliminate all flammable materials from confined spaces before persons enter. The objective should be no detectable flammable vapour, i.e. an explosimeter reading less than 1% LFL. In exceptional situations where this is not achievable, special measures have to be taken to eliminate possible ignition sources. In any event CSE shall not be allowed into spaces where the flammable concentration is greater than 10% LFL.
5.4
Toxic Hazards
Toxic substances can be solids, liquids or gases. They can cause harm by inhalation, ingestion or skin contact. They can affect the tissue at the point of contact, or organs remote from the point of contact. Toxic substances can cause injury, acute or long-latency illness, or death, depending on the characteristics of the substances, the concentration and the duration of exposure. For example, prolonged exposure to benzene can cause kidney damage or even leukaemia. Toxic hazards in confined spaces can result from the same sources as the flammable hazards described in Section 5.3. Additional hazards are: Contamination of personal protective equipment; Carbon monoxide and nitrogen dioxide, which are present in the exhaust of combustion engines; Carbon dioxide permeating from limestone containing ground into trenches.
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Common toxic substances in the oil, gas and petrochemical industry are:
Acute toxic gases such as hydrogen sulphide, carbon monoxide, hydrogen fluoride, ammonia
and chlorine;
Hazardous liquids such as benzene, polycyclic aromatics, lead/anti-knock compounds, hydrazine

and biocides;
Narcotic gases and vapours such as butane, pentane, hexane, gasoline and gas condensate; Catalyst dusts, such as nickel, platinum, and molybdenum.
Toxicity data for specific substances, e.g. material safety data sheets (MSDS), should be sought from the supplier of materials or from government authorities, and should be made available on site. MSDSs may not be available for intermediates and products of oil refinery and petrochemical processes. In this situation a competent industrial hygienist should assess the toxicity of the intermediates and products. Crude oil and refinery process streams are mixtures of many hydrocarbons that individually have significant toxic or narcotic effects. The HRA, as input to the JHA, should assess the hazards of the mixture in the situation where persons could be exposed. Specifically, the HRA should make a recommendation on whether flammability measurements are sufficient to detect harmful levels of the potentially toxic substance. Note that different criteria may be needed for: a) Confirming that the atmosphere in the confined space is safe for entry, for planned work, and b) Requiring persons to leave the space in case of an increased level during the work Substances that are harmful by inhalation normally have an assigned Occupational Exposure Limit (OEL). An Action Limit of 50% of the published OEL should be applied as the trigger for implementing specific measures for controlling exposure to the toxic substance during the confined space work, but the target should be to reduce the airborne concentration to ALARP. OEL data may not be available for some toxic dusts, sludge and other substances, in which case specialist occupational hygiene advice should be sought. Entry into confined spaces containing a concentration of toxic vapour, fume or dust between the OEL and the IDLH value shall be allowed only by exception when and it is not practical to ventilate the confined space or otherwise remove the hazard to reduce the toxic concentration. In this case it shall only be allowed when the source, nature and concentration of the toxic hazard is understood and exposure is adequately controlled by other means.. Entry into confined spaces containing a concentration of toxic vapour, fume or dust above the IDLH value shall not be allowed, except under inert gas entry conditions as described in Section 8.
5.5
Corrosive Hazards
Corrosive substances are harmful by skin or eye contact, by inhalation of a corrosive mist or vapour or by ingestion. They destroy the tissue and may leave permanent injury or scars. Common corrosive substances in the oil and petrochemicals industry are sodium hydroxide, sulphuric acid and hydrofluoric acid.
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5.6
Physical Hazards
Typical physical agents that are hazardous in confined spaces include:
Excessive noise levels from tools or machinery, which tend to be magnified by the walls of a
vessel or tank. For more details refer to Noise Guide, Shell SHC, 1991;
Heat stress, resulting from inadequate cooling of vessel or from ambient heating in hot climates.
It can be made worse by the PPE being worn. For more details refer to Management Guide to Thermal Stress, Shell SHC, 1991; Electric shock from hand lamps and other electric tools. For more details refer to Electrical Safety, HSE Advisers Panel, 2003); Radioactive sources used in certain types of level instrument, and radioactive substances present in certain crude oils or condensates. For more details refer to Ionising Radiation Safety Guide, Shell SHC, 1993.
5.7
Unsafe Conditions
Typical causes of unsafe conditions in confined spaces include: Structural failure, e.g. the internal floating cover or roof may not support a workers weight; Falling tools and materials, e.g. refractory in a furnace; Restricted working space and obstructions; Interaction between and incompatibility of different types of work, e.g. refractory stripping and inspection; Access and escape openings that are too small; Slippery floor surfaces and tripping hazards; Poor visibility due to misty or dusty conditions; Mixers or other moving parts, e.g. cooler fans that have not been adequately isolated or locked; Free flowing solids that can engulf a person and prevent escape, e.g. catalysts or sand; Flow of liquids into a drain or excavation leading to drowning or other serious injury; Improper shoring of excavations leading to collapse of the sides.
5.8
Psychological Issues
Selection of personnel to enter confined spaces should take account of the arduous nature of the work and the mental and physical requirements. Working in confined spaces can cause claustrophobia and anxiety to people who are predisposed to the condition. Usually this will be known in advance. If not it should become evident during training for confined space work. Depending on the severity of the condition, it is likely that the employee is not fit for this type of work. For more information, refer to the Fitness to Work Yellow Guide, Shell HSE Advisors Panel, 2003. If someone has narrowly escaped from a serious accident or has been witness of a serious accident, fear and anxiety may develop even after years of working without problems. If this is not addressed
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in the appropriate manner employees may become permanently unfit for confined space entry work. The impact of the arduous nature of the work in confined spaces together with the psychological and physical strains are more pronounced in cases of inert gas entry work. The consequence of a breathing mishap are swift, the effect is potentially fatal and recovery measures are much more difficult compared with a confined space where a normal (20.0 - 21.5% vol.) oxygen level exists. Inhalation of low levels of narcotic materials (hydrocarbons, cleaning solvents, adhesives etc) during confined space work may impair judgement.
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6 Controls that Apply to all Confined Space Entries
6
6.1
Controls that Apply to all Confined Space Entries

Permit to Work
All CSE work shall be controlled by means of a permit. The permit may either be a general permit, supported by a confined space certificate or checklist, or a stand-alone confined space permit, depending on the requirements of the BU or site permit to work system. Refer to Permit to Work Systems, Shell HSE Advisers Panel, 2003, for detailed guidance. For all except the lowest risk CSE a JHA or similar process should be used as part of the planning of the work. The JHA becomes an integral part of the permit. It should be used as the basis for pre-job and daily work team briefing and displayed with the permit outside the confined space. For high risk CSE, including entry into oxygen deficient and inert gas confined spaces, the permit should be approved by a higher level signatory.
6.2
Mechanical Isolation
Confined spaces should be positively isolated from all potential hazards by inserting blinds or by disconnecting and blanking all lines connected to the space. The isolation flange should be as close as possible to the vessel or tank to minimise risks of inadvertent open connections to the confined space and the risks of substances in the connecting pipe work re-contaminating the confined space. Blinds and blank flanges should be sufficiently strong to withstand the maximum internal pressure that might be exerted against them. The following methods of isolation should not be used for CSE: A closed valve, even when sealed and made inoperative; Inserting a sewer plug, an inflatable balloon or a stopple in a line; Freezing of a fluid in a line. Exceptions to the general requirement for positive isolation are allowed in the following situations: Double block valve and drain arrangements (two block valves in series with an open drain valve in between to confirm the valve isolation is effective) may be used for low hazard fluids such as water or air; Sewer plugs or air bags may be used in very low pressure water service, e.g. for isolating drain pits or interceptor pits from the connecting pipes or channels. In both these exceptional situations there needs to be a detailed assessment of the risks before accepting the lower standard of isolation, and a means of verifying the effectiveness of isolation throughout the entry period. For more detailed guidance on mechanical isolation refer to Permit to Work Systems, Shell HSE Advisers Panel, 2003.
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6.3
Electrical/Hydraulic Lock-out and Tag-out

Electrically driven equipment in confined spaces should be isolated, and the isolating switches locked and tagged to prevent inadvertent use or movement. For more detail on electrical isolation refer to Electrical Safety, Shell HSE Advisers Panel, 2003. Hydraulically or pneumatically driven equipment should be depressurised and the hydraulic or pneumatic lines should be positively isolated outside the confined space. Moving parts inside confined spaces, e.g. air cooler fans or vessel stirrers, should be isolated from drives by removing mechanical linkages and locking the moving part in position with mechanical stops.
6.4
Clearance of Process Materials

Process materials in a confined space need to be removed before entry is allowed. This is often referred to as gas freeing, and is achieved by a combination of draining, venting, displacing or flushing with water or heavy hydrocarbon, purging with steam or inert gas, chemical cleaning and finally ventilation with air. For detailed guidance refer to Gas Freeing and Cleaning of Storage Tanks, HSE Advisers Panel, 2003 and Permit to Work Systems, Shell HSE Advisers Panel, 2003.
6.5
Ventilation
Confined spaces should be ventilated with air: a) Initially to remove the gases used to purge flammable or toxic contaminants of the previous contents; b) Throughout the entry period to replace oxygen used by people working in the space, to remove vapour or fumes produced by the work and to remove vapour generated from residues, scale, pyrophoric reactions etc. Natural ventilation has the advantage that it does not depend on mechanical devices that can fail or can provide an ignition source. in contrast forced ventilation using fans or air eductors is not dependent on wind speed and direction, and is therefore more predictable and often more effective. Whichever method is chosen, man ways and vents should be selected and eductors and fans should be located so as to reinforce the natural movement of gases, i.e.: Hot gases and air tend to rise; Hydrocarbon vapours are generally heavier than air, and tend to fall. Ventilation should be arranged so that it changes the air in all parts of the confined space, including low spots and dead ends where heavy gases and vapours can collect. Refer to Gas Freeing and Cleaning of Storage Tanks, Shell HSE Advisers Panel, 2003 for detailed arrangements that can be applied to process vessels as well as tanks.
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To ensure that the air used for ventilation is not contaminated the following precautions should be taken: Surrounding process plant should be closely monitored, to identify leaking liquids or vapours. This is particularly important for confined spaces below ground level, drains and excavations, as many common contaminants are heavier than air; Any work in the surrounding area that could cause contamination of the ventilation air should be stopped; Diesel engines should not be located upwind of any ventilation air inlet, either vessel man way or compressor air inlet; Residues and waste materials should be moved well away from the confined space so as not to contaminate the ventilation air. Local exhaust ventilation may be needed to extract fumes or dust resulting from welding, gas burning and other work, when an analysis of the hazards indicates that the general ventilation is in adequate. Oxygen shall not be used to ventilate a confined space, as this could lead to oxygen enrichment of the space. When pneumatic tools are used in a confined space special care should be taken to ensure that they are not coupled up to nitrogen supplies by mistake.
6.6
Testing and Monitoring

The atmosphere both in and around the confined space should be tested before entry to determine if entry criteria are met. Tests should be repeated at regular intervals while work is in progress and always after a break in the work. The permit for the work should specify the tests needed and the test frequency. Gas tests should be carried out in such a way that the results are representative of conditions in the entire space. Particular attention should be paid to the direction of flow of ventilation air and to locations where toxic or flammable gases may accumulate, e.g. in sumps. The preferred method is for gas tests to be carried out from outside the confined space, using sample probes attached to the testing equipment. The time lag when drawing a sample through a probe should be allowed for. Entry to clean a tank or vessel can disturb scale or sludge and result in a locally high concentration of flammable material, even if the confined space was gas free before entry and forced ventilation is applied. This situation is acceptable providing the excursion is limited to an area immediately surrounding the point of disturbance and the bulk of confined space is controlled within the allowable limit.
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Testing equipment should be:
Specific to the gases that have to be tested and sensitive at the OEL; Of an approved type, e.g. intrinsically safe; Designed to give an a visual and audible alarm, when being applied for monitoring as opposed to
one-off testing;
Correctly maintained and calibrated; Checked that is functioning correctly, at the start of each day.
CSE testing should be carried out by a competent, authorised gas tester, who has been trained in the use of the equipment, understands the limitations of the equipment and can interpret the results correctly. The gas tester should wear the appropriate PPE until the test results confirm that the hazard is controlled. Test results should be recorded on the permit for the work or a gas test certificate. If it becomes necessary to enter the confined space to obtain a representative sample, entry of the competent person, normally the permit issuer rather than an authorised gas tester, should only be allowed when all the controls specified on the entry permit, apart from the gas test, are implemented and effective. When the JHA indicates that conditions could change and hazardous gases could build up in the confined space during the work, the space should be continuously monitored. The optimum location of the gas test equipment within the confined space is determined by the type and direction of ventilation and the potential for heavier than air gases to build up in low points. It is recommended to use personal monitors, e.g. attached to the lapel, when it is uncertain whether the installed gas detectors or portable gas detectors will provide a rapid warning of gas build up. In the rare situations where forced ventilation is being applied to control the concentration of a flammable, toxic or asphyxiant hazard, continuous monitoring for the hazardous gas is essential.
6.7
Control of Ignition Sources

Potential ignition sources are described in Section 5.3. The recommended approach is to eliminate ignition sources by means such as: Use intrinsically safe electrical equipment where available, e.g. gas testing equipment, radios, pneumatically driven lights; Use approved electrical equipment that has been regularly tested and inspected before use. For details refer to Electrical Safety, Shell HSE Advisers Panel, 2003; Earth any equipment that can become charged with static electricity, e.g. ventilation eductors and hoses, spray painting guns, and ensure that vessels are earthed; Select PPE that does not become charged; Remove pyrophoric scale or keep it wetted until it can be removed;
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Locate diesel engines and other internal combustion engines well away from the confined space; Prevent mechanical sparks, e.g. from falling tools.
When ignition sources cannot be totally eliminated they should be strictly controlled through the Permit to Work system.
6.8
Control of Radiation Sources

Radiation sources are used in certain types of level instrument. They should be removed or shielded. For more detail refer to Ionising Radiation Safety Guide, Shell SHC, 1993.
6.9
Lighting and Electrical Equipment and Tools

As indicated in Section 6.7 lighting and electrical equipment used in confined spaces should be intrinsically safe whenever possible, and otherwise of an approved type that has been regularly tested and inspected before use. They should be fitted with an Earth Leakage Current Device or other approved means of protecting users against electric shock. For more details refer to Electrical Safety, Shell HSE Advisers Panel, 2003.
6.10
Internal Combustion Engines and Gas Cylinders

Petrol fuelled engines should not be used inside confined spaces because of the increased risk of a flammable atmosphere and ignition by the engine ignition system. Diesel driven engines should be located outside the confined space at a safe location where exhaust fumes cannot contaminate the atmosphere inside the confined space, either directly or through forced ventilation or breathing air systems. In the exceptional situations where diesel engines have to be used in the confined space, e.g. diggers in excavations or dumper trucks in large storage tanks, sufficient ventilation should be applied to prevent the build-up of harmful fumes. The atmosphere should be continuously monitored. Engines should be refuelled outside the confined space. The need for gas supplies into confined spaces should be eliminated as far as possible, e.g. by not using gas operated lights or gas welding and by designing out the need for inert gas welding in confined spaces. Gas cylinders supplying gas for oxy-propane cutting or propane burning should be kept outside the confined space, and the hoses and equipment should be carefully inspected before use. Gas supplies into the confined space should be closed and the hoses and equipment removed to an open area during work breaks and at the end of each day.
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6.11
Personal Protective Equipment (PPE)

Breathing apparatus, and respirators, that are suitable for entry into atmospheres containing to toxic vapours, fumes and dusts and into oxygen deficient atmospheres are described in Section 7.0. Protective suits, boots and gloves may be needed when there is a risk of contact with toxic or corrosive chemicals. When specifying the use of protective clothing consideration should be given to the risk of increasing heat stress, and the need for appropriate work patterns. For more details refer to Personal Protective Equipment, Shell SHC, 1989.
6.12
Access and Escape

Sufficient man way covers and internal fittings should be removed from tanks or vessels and adequate steps and ladders should be fitted to enable: Equipment and persons to be moved into and out of the space; Space for the intended work; The attendant to keep persons under observation; Persons to escape in an emergency. When the JHA indicates the possibility of toxic gases building up in the space as a result of changes during the work, persons entering the confined space should carry escape respirators, e.g. ten minute air bottles or chemical re-breathers. Escape sets should not be used as short term work breathing apparatus. Precautions should be taken prevent unauthorised or accidental entry into confined spaces. When work is temporarily suspended barricades and warning notices should be provided at the access points. The safe system of work should include a box-up procedure that ensures everyone is out of the confined space before the man way is boxed-up on completion of the CSE.
6.13
Attendants
The permit, JHA and/or rescue plan should identify the number of attendants needed for the different phases of the work and it should detail their responsibilities. Typical responsibilities and competences of attendants are detailed in Appendices 1 and 2. An adequate and effective means of communication should be established before persons enter the space: Between the persons inside a confined space; Between the persons inside a confined space and the attendant outside; Between the attendant and the control room and/or emergency response team.
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Communication can be by speech, tugs on a rope, telephone or radio (intrinsically safe when flammable conditions could exist). It is important that communication is easy and effective, therefore, it should be practised.
6.14
Fitness to Work
The fitness of persons who will enter a confined space, and of the rescue team, should be considered as part of the HEMP, especially in case of difficult access, heavy manual work, high temperatures or where breathing apparatus and chemical suits have to be used. Section 5.5 and 5.6 describe the physical and psychological factors that can impinge on fitness to work. For more details refer to Fitness to Work, Shell HSE Advisers Panel (2003).
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7 Entry Criteria and Specific Controls
Entry Criteria and Specific Controls

This section sets out the criteria to determine whether entry is allowed. It then describes the controls specific to the particular entry conditions. The controls that are common to all confined spaces are detailed in section 6.0. Normal Without breathing apparatus Oxygen % Toxics ppm Flammables % LFL 20 to 21.5 < OEL Not detectable (<1) Exceptional With breathing apparatus 16 to 20 OEL to IDLH < 10 For hot work - not detectable
Entry shall not be allowed into confined spaces outside these limits, where oxygen is less than 16% vol. or toxics are above IDLH limit or flammables are above 10% LFL, except for: Entry by specialist rescuers using breathing apparatus with back-up air supplies, specialist attendants and communication systems; Inert gas entry by specialist catalyst handling contractors, as described in Section 8 of this document. Notes 1. At high altitudes the atmospheric oxygen content drops below 20%. For these situations the oxygen criterion should be adjusted. 2. The IDLH value of toxic substances, and the equivalent for oxygen of 16% vol., is selected as the limit for use of conventional breathing apparatus. The logic for this is that the IDLH value is the highest level (lowest in case of oxygen) at which a person can escape from the space or area without assistance. There have been a number of fatal incidents over the years in Group activities where breathing air supplies have failed or persons have removed their air mask whilst still in the hazardous atmosphere. It is therefore considered prudent not to depend wholly on speedy rescue arrangements in case of an air supply failure, but rather set a limit such that persons should be able to escape unaided. 3. The toxic IDLH criteria should not be applied for work in open areas with breathing apparatus. 4. %LFL is a combined measure of the fire/explosion hazard, and of the toxic hazard of general hydrocarbons, when the HRA and JHA establish that there are no specific toxics present. 5. If any one of oxygen, toxics or flammables does not meet the Normal criterion, supplied air breathing apparatus shall be worn.
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7.1
Normal Confined Space Entry Without Breathing Apparatus

In addition to the general controls in section 6.0, the following specific controls should be applied. Ventilation should be sufficient to ensure that the confined space is kept free of toxic vapours, fumes or dusts in excess of the OEL, and is maintained at an atmospheric oxygen content (20 to 21.5 % vol.) Air purifying respirators (canister masks and cartridge masks) may be used in confined spaces where the oxygen content is between 20 and 21.5 % and the level of toxics is below OEL x Protection Factor and below the IDLH value. A procedure for changing and controlling canisters or cartridges should be rigorously applied to ensure that they do not become saturated in use. Note that the practical Protection Factor of air purifying respirators can be several times lower than the often quoted Nominal Protection Factor (NPF). It is recommended to apply the OSHA values of 10 for half face mask and 50 for full face mask. There shall always be an attendant on standby outside the confined space. The need for harnesses, lifelines, escape breathing apparatus and presence of rescue personnel should be considered when preparing the rescue plan.
7.2
Exceptional Confined Space Entry With Supplied Air Breathing Apparatus

Every effort should be made to ventilate a confined space, to remove all contaminants and to establish an atmosphere oxygen concentration, so that entry is possible without breathing apparatus. In exceptional situations the contaminant cannot be entirely removed and the oxygen content remains below 20%, for example: Drains or sewers that cannot be positively isolated, and which may be difficult to ventilate; Storage tanks containing sludge which releases flammable vapours when disturbed; Trenches where nitrogen is being used to freeze isolate a pipeline. In these situations it is essential that the JHA identifies the source of contamination and provides for ventilation that will ensure that the atmosphere in the confined space is stable, i.e. oxygen level will not reduce further and will remain above 16% vol. The potential for the hazard to cause harm has to be understood and controlled. Ventilation should be continued throughout the entry period to maintain the oxygen as close as possible to atmospheric level and the toxic and flammable levels as low as reasonably practicable. In any event the oxygen, toxics and flammable criteria shall be maintained throughout the entry period. When ventilation is applied to control a flammable, toxic or asphyxiant hazard the atmosphere inside the confined space should be monitored continuously.
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Supplied air breathing apparatus should meet the following specification:
When air is supplied from a breathing air compressor, a bank of cylinders or a breathing air
supply main, the supply system should be reliable with sufficient back-up capacity in case of compressor or supply main failure. Persons operating the air supply system should be well trained and competent in their duties. (Note that there have been fatalities in Group activities as a result of air supplies failing); When breathing air is supplied from a compressor or supply main, separator vessels, filters or other equipment may be needed to remove water, oil or particulates from the supplied air. The compressor air intake should be located so that the supplied air is not contaminated by fumes from the diesel exhaust or other sources. If there is any doubt the air intake should be continuously monitored and installation of automatic shutdown (Chelwyn) valves should be considered; Breathing air mains should be segregated from instrument air, tool air and protected against possible contamination, e.g. by connection to hydrocarbon or nitrogen systems; Hoses supplying breathing air to a confined space should be located, suspended or otherwise guarded to avoid accidental damage. In addition these hoses should be inspected for leaks prior to use; When self-contained breathing apparatus is used, cylinders should be of sufficient capacity for the duration of the work; Air masks should be full face, and should be of the positive pressure demand type; Air purifying respirators shall not be used.
There shall always be one or more attendants, as established by the JHA and rescue plan, on standby outside the confined space.
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8 Inert Gas Confined Space Entry for Catalyst Handling
Inert Gas Confined Space Entry for Catalyst Handling

The main application of inert gas CSE in the Shell Group is for removal of spent catalysts from hydroprocess unit reactors. By keeping the catalyst under inert gas conditions whilst it is removed to a catalyst reprocessing plant, degradation of the catalyst is avoided and the need for time consuming regeneration of catalyst in the reactor can be eliminated. Thus the turnaround time of the unit can be shortened. The work is inherently hazardous because persons in the inert atmosphere are totally dependent on their breathing air system for survival. Also, any oxygen entering the confined space can cause the catalyst to ignite. Management shall apply the HEMP process to the proposed inert gas entry activities to demonstrate that there is no reasonably practicable alternative to inert gas entry, and that the planned controls will reduce the risk to ALARP. This type of work is usually performed by highly experienced specialist contractors, whose specialist knowledge is critical in the planning and implementation of a safe system of work. The intention of this section is to detail the hazards, controls and entry criteria, specific to inert gas confined spaces.
8.1
Hazards
The confined space hazards described in Section 5.0 of this document apply to inert gas confined spaces, except as amended here. Loss of Breathing Air Supply There is an immediate risk to life should a person working within the space panic and remove their air mask, have the mask dislodged or lose air supply for any reason. Oxygen Deficiency at Man Ways One or more of the reactor man ways have to be kept open to allow people and equipment to enter the reactor. The area up to a few metres away from the man way will have an oxygen level lower than atmospheric as a result of inert gas leakage from the space. Workers and attendants in this area should wear positive pressure demand full-face mask breathing apparatus. Barriers and warning signs should be installed to keep other people away from this area. Fires and Explosions from Ingress of Air Fires in reactors can result from residual hydrocarbons, coke on the catalyst, carbon monoxide or pyrophoric iron sulphide if oxygen is allowed into the reactor. The main control is to maintain inert gas supply to the reactor, so that the oxygen level in the space remains below 3%. This figure includes a safety margin with respect to the theoretical maximum oxygen content of 8 to 10% to avoid a flammable mixture.
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Certain compounds contain chemically bonded oxygen, which can be released in a combustible atmosphere. Examples are nitrates, peroxides and hydrocarbon oxides, for which specialist advice should be sought. Even when the atmosphere in the reactor itself is not flammable, gas leaving the space through open man ways may mix with air and result in a flammable mixture, and a fire/explosion hazard to persons outside the space. For this reason the entry criterion is to maintain the flammable gas level inside the confined space below 10% LFL. Note that the normal flammability detectors work on the principle of measuring temperature rise from combustion. They will not work in inert gas atmospheres, therefore special equipment is needed that is based on a different principle. These detectors are available from several of the wellknown gas detector manufacturers. Toxic gases The most common toxic gases present whilst handling catalysts under inert gas conditions is hydrogen sulphide. However, the HEMP and gas tests may identify other toxic gases such as carbon monoxide or nickel carbonyl. Given that high integrity breathing apparatus is already needed to assure the breathing air supply to those persons working in inert gas confined spaces, entry is allowed when the toxic concentration is above the IDLH value. The upper airborne concentration allowed for a toxic gas may be fixed by flammability criteria, e.g. for hydrogen sulphide or carbon monoxide, or by the protection factor of the breathing apparatus being used. Also, at these high levels of toxic gases other ways of absorbing the toxic substance into the body should be considered. It may be necessary to specify total coverage impermeable clothing to achieve full protection. The upper airborne concentration allowed for the toxic gas should be determined by industrial hygiene specialists for the individual substances identified. Nickel Carbonyl Nickel carbonyl is a hazardous chemical that is unique to processes using catalyst containing nickel. It is a highly volatile chemical formed by the reaction of carbon monoxide with nickel. Inhalation of concentrations of only a few parts per million for short periods may cause acute symptoms. A concentration of 30 ppm for 30 minutes is known to be lethal. The IDLH value is 2 ppm. Heat Stress The main application of inert gas entry is replacing catalysts without first regenerating them, thereby achieving a quick turnaround of the unit. There is liable to be pressure to minimise the vessel cooling time with possible negative impact on the potential for heat stress on individuals required to work in the confined space. Therefore it is critical to understand the causes of heat stress and how to assess these so that appropriate controls can be put in place, including identifying a maximum temperature that may be allowed, to safeguard personnel whilst in the space.
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In general, the likelihood of heat stress increases when the temperature and/or humidity in a confined space are high, when the work done is abnormally strenuous or when impervious protective clothing is used which prevents the ability of a person to help to control their body temperature by sweating. For further details on calculation of heat index and recommended work patterns refer to The Management Guide to Thermal Stress, Shell SHC, 1991 and additional references given under Section 9.0. Catalyst Beds Catalyst that is being removed from a reactor is liable to sudden movement or collapse, which can lead to workers either falling or being engulfed. Workers should therefore wear harnesses and lifelines. The build-up of pressure inside a catalyst bed can lead to the crust rupturing violently.
8.2
Equipment and Resources

Inert Gas Supply The quality and reliability of the inert gas supply should be verified to ensure that the inert atmosphere is maintained. The following elements should be checked before entry: The composition of the gas should adequately inert the atmosphere. The oxygen content of nitrogen should be less than 100 ppm; There should be an adequate quantity and flow rate of the gas to inert the space and to feed the leakages from open man ways and nozzles, for the intended duration of the work; Any pneumatic tools should be supplied from nitrogen, not air; There should be no build up of pressure in the confined space. The inert gas supply should be continuously monitored and the responsibility for doing so should be clearly defined. Flow and pressure indication are recommended. The oxygen content of the space should be continuously measured. In case of loss of control of the inert gas supply persons inside the space should be evacuated immediately. Breathing Air and Communication Systems The following lists the minimum requirements: A positive pressure demand breathing apparatus with full-face mask for each person who will enter the confined space, and for the attendant. Use of air-supplied helmets may be considered as an alternative to full-face masks; Two completely independent air supplies for each person who will enter the confined space, and for the attendant; Banks of air cylinders that are manifolded in such a manner that the two independent air supply lines are provided for primary and emergency use. The emergency air supply should be sufficient to allow persons to evacuate the confined space. Each person who will enter the space and the attendant outside should have an escape air bottle attached as close as possible to their mask, i.e. totally independent of the primary and emergency air supplies;
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Life support control station, set up as close to the entry point as practicable to continuously
monitor the supply air pressure to individual masks. Each breathing apparatus should be provided with an alarm indicating low supply pressure and an automatic actuating valve for the emergency air supply. It should be transparent how the system copes with a total failure of air supply from outside the confined space; The control station should also be capable of monitoring the atmospheric conditions in the confined space, e.g. oxygen and temperature; The control station should be provided with a battery power back up, automatically cutting in on failure of electricity supply. The battery supply should keep communication systems alive as well as providing emergency lighting at least for the time needed to evacuate persons from the confined space; Open communication links between entry personnel, attendants, supervisors and emergency personnel; Reinforced umbilical cords linking each person in the confined space with the monitoring station and carrying primary and emergency air supplies and communication cables; Safety harness and lifeline. Fall arrestors are commonly used; A hoisting device capable of assisting in rescuing persons from the confined space; A supply of emergency compressed air cylinders of sufficient capacity for rescue purposes; Persons required to approach the CSE area, but not actually enter it, should wear positive pressure demand breathing apparatus. Additional sets should be available outside the reactor for rescue personnel.
Other Equipment The provision of an oxygen resuscitator outside the space should be considered. However, this requires an individual trained in its use and holding a current certificate in cardiopulmonary resuscitation. Means of carrying injured persons from reactor platforms to ground level should be provided, e.g. a crane and stretcher. Safe access should be provided into and within the space, using the appropriate ladders, platforms and lighting. Rope ladders should be avoided unless users are trained and experienced in their use. Pneumatic powered tools or lights should be supplied by nitrogen to prevent oxygen being introduced to the confined space. People The following people are normally required: Technicians working in the reactor. Numbers should be kept to a minimum, to reduce the risk; Console operator, who monitors and records conditions of the technicians in the reactor, reactor conditions and equipment performance; Attendant at the man way, who assists the console operator and supervisor to maintain the breathing air supplies and the line of communications to the technicians inside the reactor. The attendant should be wearing a full inert gas suit and breathing apparatus, and be ready to respond in an emergency;
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Supervisor and one or more assistants.

When catalyst is being handled at elevated positions, supervision should be divided between the top and ground levels. For multi-bed reactors, where work is taking place at several levels simultaneously, the number of attendants and assistants should be increased.
8.3
Managing Specialist Contractors

The specialist catalyst handling contractors who carry out inert gas entry work have much more practical experience in the techniques than Shell operating companies. They will normally supply their own breathing apparatus, communication systems and rescue equipment. Their know-how should be fully utilised in the HEMP, which should be conducted during planning of the work. However, it is essential that the Shell site managers and engineers are familiar with the standards that should be applied (described in this document) and are able to assess the capability of contractors who are bidding for catalyst handling work. Site management should be satisfied that the selected contractor is both competent and will work to HSE standards comparable to Shell standards. The specialist contractors should meet standards in Section 8.3 related to equipment and people. In addition they should provide the following information: A comprehensive safety and operating manual covering the procedures and instructions needed to perform inert gas entry work; Training certificates for the persons selected for the work, to show their capability for entry into inert atmospheres and their ability to communicate in the agreed working language; Confirmation that all selected persons are qualified for inert gas entry work, and will undergo regular medical checks; Written reports of similar work undertaken; Incident reporting procedures and safety records. There should be close cooperation between Shell and contractor staff from the planning stage onwards. Responsibilities of the two parties should be clearly defined, understood and strictly adhered to.
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9 References
References
Shell Safety and Health Committee and HSE Advisers Panel publications: Electrical Safety (2004) Fitness to Work (2003) Gas Freeing and Cleaning of Storage Tanks (2003) Health Risk Assessment (2001) Management Guide to Thermal Stress (1991) Noise Guide (1991) Permit to Work (2003) Personal Protective Equipment (1989) Radiation Safety (1993) Risk Assessment Matrix (1999) Other publications:
Job Hazard Analysis, EP 95-0311 Hazard Identification, EP 95-0312 Guidelines for Work in Inert Confined Spaces in the Petroleum Industry, API Publication 2217A,
1997 Safe Work in Confined Spaces, L101, UK Health and Safety Executive, 1997 Respiratory Protective Equipment, HS(G)53, UK Health and Safety Executive, latest edition Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks, API Publication 2016 Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks, API Publication 2015 Permit Required Confined Space Standard, US OSHA 29 CFR 1910.146 Respiratory Protection Standard, US OSHA 29 CFR 1901.134 BS4275:1997: Guide to implementing an effective respiratory protective device programme BS7963:2000: Ergonomics of the thermal environment: Guide to the assessment of heat strain in workers wearing personal protective equipment ISO12894:2001: Ergonomics of the thermal environment: Medical supervision of individuals exposed to extreme heat and cold environments ISO9886:1992: Evaluation of thermal strain by physiological measurements
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10 Glossary
10
Glossary
As Low As Reasonably Practicable (ALARP) For detailed guidance refer to Risk Assessment Matrix, HSE Advisers Panel, (1999) Business Unit (BU) Activities in one of the Group businesses that are operated as a single economic entity. A business unit can coincide with a Group company or straddle part or all of several companies. Confined Space A fully or partially enclosed space where there is a risk of serious injury from hazardous substances or conditions within the confined space or nearby. Common examples of confined spaces are: Process vessels, including columns, column skirts, large pipes, flare stacks, boilers, storage tanks, road/rail tankers; Spaces below ground or deck level, such as drain pits, sewage pits and associated tunnels, trenches, wells, shafts; Cargo holds, ballast tanks, engine rooms or void spaces on ships; Support columns, legs or pontoons of fixed or mobile off-shore installations. Other types of confined space are less obvious, for example: Rooms that are inadequately ventilated; Rooms that become confined because of the type of work being undertaken, e.g. spray painting; Open top tanks or on the roof of floating roof tanks; Excavations. Partially enclosed areas such as pits, excavations and tank roofs are considered to be confined spaces when they are deep enough for the breathing zone to be inside the pit (typically more then 1.5 metres) and the ventilation is insufficient to prevent possible build up of hazardous vapours. When the width (narrowest side) of such an area is less than six times the depth ventilation will be insufficient (The Institution of Petroleum Area Classification Code). Examples of hazardous substances and conditions within a confined space are: Oxygen deficiency leading to asphyxiation or unconsciousness; Toxic vapours, fumes or dusts; Flammable or combustible materials leading to fires or explosions; Free flowing solids or rising liquid level leading to engulfment, asphyxiation or drowning; Excessive temperatures leading to heat stress and unconsciousness; Inadequate lighting. A more complete description of hazardous substances and conditions is contained in Section 5.0 of this document.
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10 Glossary
Confined Space Entry (CSE) Entry means either complete body entry or inserting a head into man way openings, hatches, pipe ends etc. Health Risk Assessment (HRA) The identification of health hazards in the workplace and subsequent evaluation of risk to health. This assessment takes into account existing or proposed control measures. Where appropriate, the need for further measures to control exposure is identified. For more details refer to Health Risk Assessment, Shell HSE Advisers Panel, 2001. Inert Gas Confined Space A confined space where the existing atmosphere is intentionally displaced with an inert gas such as nitrogen, to prevent ingress of air and oxidation of catalyst or other contents of the space. Immediately Dangerous to Life and Health (IDLH) IDLH is defined by OSHA as 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 individuals ability to escape unaided from a permit space. The National Institution of Occupational Safety and Health (NIOSH) defines the purpose of establishing an IDLH as to ensure that the worker can escape from a given contaminated environment in the event of failure of the respiratory protection equipment. NIOSH has established IDLH values for a number of chemicals that are toxic by inhalation. When an IDLH is not available, specialist advice should be sought to establish an equivalent to IDLH. Job Hazard Analysis (JHA) A job hazard analysis (JHA) is a method for analysing the hazards and identifying the controls and recovery measures needed to control the hazards. It is a step in the application of the Hazards and Effects Management Process (HEMP) to operations, maintenance and construction activities. For more details refer to EP 95-0311. Job Safety Analysis (JSA) and Task Safety Analysis (TSA) are equivalent terms. Lower Flammable Limit (LFL) The lower flammable limit of a hydrocarbon or other flammable vapour in air, above which the vapour will burn when ignited. Concentrations are normally expressed as % LFL. Lower Explosive Limit (LEL) is an equivalent parameter. Occupational Exposure Limit (OEL) The airborne concentration of chemical agents and levels of physical agents, to which workers may be repeatedly exposed day after day without adverse effect. Commonly used terms applied in some countries are Maximum Exposure Limit (MEL), Maximum Allowable Concentration (MAC) and Threshold Limit Value (TLV).
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Appendix 1 Responsibilities of key personnel
Appendix 1
Responsibilities of key personnel
Operations supervisor (Permit Issuer) The Operations supervisor fulfils the Permit Issuer responsibilities as detailed in Appendix 4 of Permit to Work Systems, HSE Advisers Panel (2003), and reproduced here: The Permit Issuer works under the delegated authority of the Asset Owner and is responsible for: Confirming that all hazards associated with the work have been identified and all relevant parties have provided their input and agree with the precautions, e.g. through supporting certificates and JHAs; Ensuring that all necessary supporting certificates, job hazard analyses and drawings are attached to the permit; Confirming that all operational preparations, including process clearance and isolations, have been completed; Confirming that the work site is safe for the work to proceed; Specifying on the permit any additional precautions that need to be taken during the work, including use of safety equipment and PPE; Identifying any conflicts between the proposed work and other activities in the area, and if necessary cross referencing the permits; Informing all people who may be affected by the work; Ensuring that the Permit Holder knows the exact location of the work, all the hazards that may be present and all the precautions that must be taken during the work; Signing and issuing the permit; Knowing the status of the work at all times, e.g. on a display board, and communicating the status to the oncoming shift at shift handover; Signing off and cancelling the permit when the work is complete or suspended. In addition the Operations supervisor is responsible for: Making an initial inspection of the confined space before allowing entry; Maintaining adequate ventilation of the confined space; Ensuring that the supervisor in charge of the work and the attendant are fully familiar with the specific flammable, toxic and asphyxiant hazards of the particular confined space, and with the precautions that must be taken; Setting up an entry log at the entrance to the confined space and briefing the attendant on how to maintain the entry log. Operations supervisor means a person in the Operations or Asset Owner organisation who has the above responsibilities. It could equally well be a senior operator or a plant manager.
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Supervisor in charge of the work (Permit Holder) The supervisor in charge of the work will fulfil the Permit Holder responsibilities detailed in Appendix 4 of Permit to Work Systems, HSE Advisers Panel (2003), reproduced here: The Permit Holder is responsible for: Discussing the job fully with the Permit Issuer before signing to accept the permit; Showing the work party the exact location and equipment to be worked on; Explaining to the work party the details of the work, any potential hazards and precautions to be taken; Ensuring that the precautions are maintained throughout the work, and that the work party and the work stays within the limits (area, types of work, time) specified on the permit; Displaying the permit and attachments at the work-site; Stopping the work and seeking advice from the Permit Issuer if conditions at the work-site change; Ensuring that the work-site is left in a safe and tidy condition before handing back the permit on completion or suspension of the work. In addition the Supervisor is responsible for:
Briefing the work team on the methods of access and egress and the plans for escape should an
emergency arise; Liasing closely with the attendant and making sure that the attendant is familiar with the work in progress, the hazards involved and how to communicate with the emergency services; Stopping the work and withdrawing the work group should conditions develop in or around the confined space that are not allowed by the permit.
Attendant (Standby) The Attendant outside the confined space is responsible for: Knowing the hazards that may be faced by persons in the space, including toxic exposure symptoms and how persons react to those hazards; Maintaining contact with the persons inside the confined space. Where visual contact cannot be maintained radio should be used; Maintaining contact with the control room and/or emergency response team; Monitoring activities inside and outside the confined space, and ordering an evacuation should persons inside the space show behaviour that indicates they are being affected by hazardous conditions, or should conditions outside the space pose a threat to those inside; Ensuring, when breathing apparatus is being used, that the air supply from outside the confined space is maintained and is safeguarded against contamination. (It may be necessary to allocate a separate person to control the air supply); Maintaining a record of numbers and names of persons who are in the confined space at any one time, e.g. by an entry log; Barricading an area around the confined space or entry point and keeping unauthorised persons out of this area. Making sure that barricades and warning signs are in place during breaks and at the end of the day; Raising the alarm by alerting the rescue team in case of any emergency in the confined space; Remaining in attendance outside the confined space until relieved by another attendant; Assisting in any rescue that might be necessary. The attendant must not attempt a rescue that involves entry before the emergency services arrive, as this would leave the outside unattended.
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The attendant should be dedicated to the above duties and should not act as a supervisor. In case of a large, complex confined space or of breathing apparatus entry by several persons, more than one attendant may be needed. The number of attendants should be identified by the JHA and the rescue plan. Persons entering a confined space (Entrants) The persons entering a confined space are responsible for: Knowing the hazards that may be faced during entry; Using correctly the breathing apparatus, harness and lifeline, radio or any other equipment that is specified on the JHA and permit; Keeping in communication with the attendant; Alerting the attendant if there is any warning sign or symptom of exposure to hazards in the space; Leaving the space quickly when ordered to do so by the attendant or supervisor in charge.
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Appendix 2 Competence profiles of key personnel

These generic competence profiles can be used as a basis for defining the knowledge and skill requirements in the BUs competence management system. For further guidance on competence management refer to EP 95-0120 and the OP Business Level HSSE MS, Appendix 1 Requirements for HSE Competence Assurance in Oil Products. Operations supervisor (Permit Issuer) Have a full working knowledge of the PTW system, including the roles of signatories and others; Have a full working knowledge of confined space entry procedures and good practice, including operation of an entry log; Have a detailed knowledge of the processes and operations for which he/she is responsible; Fully experienced in all operational preparations for confined space entry, including isolation, clearance of process materials, ventilation and gas freeing; Able to explain how risk assessment, job hazard analysis and PTW systems integrate with the job planning process to provide a safe system of work; Lead multidisciplinary teams to develop safe systems of work for high risk, non-routine tasks such as confined space entry; Able to access and understand sources of information that maybe used to give insight to hazards and appropriate controls (incident reports, safety audits, workforce consultation); Identify any conflicts between the proposed work and other activities in the area and consult others as appropriate; Monitor effectiveness of the controls applied and alter them if necessary to maintain a safe system of work; Recognise changes in process conditions or the working environment that may require work to be stopped; Fully familiar with the statutory requirements and Company regulations related to confined space entry; Fully familiar with the operation of gas testing equipment, its calibration and the acceptable limits for the commonly found gases. Supervisor in charge of the work (Permit Holder) Have a full working knowledge of the PTW system, including the roles of signatories and others; Have a full working knowledge of confined space entry procedures and good practice, including operation of an entry log; Have a detailed knowledge of relevant procedures and work instructions, including those associated with maintenance and shutdown activities; Able to explain how risk assessment, job hazard analysis and permits integrate with the work planning process to provide a safe system of work; Participate in multidisciplinary teams to develop safe systems of work for high risk, non-routine tasks, such as confined space entry and rescue plans; Able to find and understand sources of information that may be used to give insight to hazards and appropriate controls (incident reports, safety audits, workforce consultation);
36
Have a full working knowledge of the responsibilities of the attendant and able to liaise with the
attendant in implementing rescue plans and setting up rescue equipment; Explain the activities, hazards and controls in daily team meetings and in toolbox talks; Supervise confined space entry work. Able to identify changes in conditions or activities that require the work to be stopped.
Attendant (Standby) Understands the typical process and physical hazards of confined spaces; Understands the working of breathing air supply systems, where supervising this system is part of the duty; Knows how to operate an entry log; Has the confidence to stop the work, withdraw the persons from inside the space and raise the alarm, in case of an emergency situation arising; Able to communicate in the agreed working language; Fully trained and certified competent in the duties of an attendant. Persons entering a confined space (Entrants) Be fully familiar with the hazards and controls for working in confined spaces; Trained and competent to use the specified equipment, such as breathing apparatus, harness and lifeline; Understand the importance of complying fully with all the controls on permits and supporting certificates and of reporting any deviations from specified conditions; Physically fit for the work and not liable to suffer from claustrophobia; Participate in daily team talks.
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Appendix 3 Rescue plans
Appendix 3 Rescue plans

A rescue plan shall be developed for each confined space. The following factors should be considered: Does the layout of the confined space make it difficult for workers and rescuers to move around? For example, offset man ways in the trays of a distillation column may make rescue very difficult. Removal of the complete trays may have to be considered in planning the work; What are the possible conditions of persons to be rescued, e.g. injured by fall, injured by falling objects, electrocuted, unconscious? Can stretchers be taken into the confined space or will incapacitated persons have to be dragged or lifted out of the space? Which direction should incapacitated persons be taken out of the confined space? Can they be carried or are winches/retrieval systems needed? Note that even the strongest person is unlikely to be able to lift an unconscious person on their own with only a rope. Do persons in the confined space need to be wearing harness, and lifeline, throughout the work period? Lack of space may make it difficult to put on a harness when needed; Will rescuers have to wear breathing apparatus? If so, is there room to move within the space whilst wearing breathing apparatus? How will the breathing apparatus and spare cylinders for rescue purposes be provided? Will the persons in the confined space be able to communicate with the attendant outside in case of an emergency? How will the attendant outside the space raise the alarm? Radio, mobile phone, siren? How quickly can the rescue team be in attendance? Can medical personnel/paramedics be in attendance in time to resuscitate unconscious persons? If not, are the rescue personnel able to resuscitate and stabilise the casualty until medical assistance arrives? Should resuscitation equipment be provided at the confined space? Are available personnel or rescue team competent to use it? How will Operations personnel certify that the space safe to enter for rescue purposes? Is gas testing equipment available?
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H S & E Publications Issued under the Auspices of the Shell HSE Committee/HSE Advisers Panel
Royal Dutch/Shell Group Health, Safety and the Environment Commitment and Policy (1997), reviewed 2000 Royal Dutch/Shell Group Procedure for HSE Management Systems (1997) Group HSE Management System (2002) HSE Management System, Integrating HSE into the Business (1994) only elec. Group Health, Safety and Environmental (HSE) Auditing Guidelines (2001) Group HSE Performance Monitoring and Reporting (2003) only elec. HSE Management Systems Management Information (1998) HSE Management Systems Incorporating Health Risks in an HSE Management System and HSE Cases (1998) HSE Management Systems Incorporating Environmental Risks in an HSE Management System and in HSE Cases (1999) Risk Assessment Matrix (1999) Occupational Health Guidelines Asbestos (1986) Chemical Hazards: Health Risk Assessment and Exposure Evaluation (1995) Fitness to Work Management Process (2003) Health Guidelines for Catering (1995) Health Risk Assessment (2001) Human Factors Engineering (HFE) in New Facilities Projects (2003) An Introduction to Health Risk Assessment: Training Package (2002), available through Open University,
see: http://sww-openuniversity.shell.com/scripts/dlmisapi.dll/GET?file=frameset.jsm&rshost=sww-openuniversity.shell.com&rsport=1564 Go to e-learning and then HSE and S
Legionella Management Process (2004) Management Guide to Thermal Stress (1991) Management Guidelines for Hearing Conservation (1991) Man Made Vitreous Fibres (2002) Medical Emergency Guidelines for Management (2001) Noise Guide (1991) Personal Protective Equipment Guide (1989) Repetitive Strain Injury (RSI) in the Office Environment (2002) The Use of Contact Lenses in Industry (1984) leaflet Safety Guidelines Company-Organised or Supported Social Events - Safety Considerations (1990) leaflet Contractor Safety (1987) Diving Operations Management Guidelines (1991) Electrical Safety (1986) Enhanced Safety Management (1985) Enhanced Safety Management Checklist (1989) Gas-freeing and Cleaning of Storage Tanks (2003) Guidelines for Entry into Confined Spaces (1992) Guidelines for Laboratory Safety (1989) Hand Tools and Sparking Hazards (1982) leaflet Hotel Fires, Plan for Survival (1988) leaflet Hydrogen Sulphide (1986) Incident Classification, Investigation and Reporting (2002) Ionising Radiation Safety Guide (1993) Office Safety (1987) Oxygen - A Hazard (1982) leaflet Permits to Work Systems (2003) Personal Protection of Helicopter Passengers in the Event of Ditching (1995) Road Transportation of Goods, Equipment and Product (2003) Safety Features of Light Vehicles and Mini Buses (1997) Safety Signs and Colour Coding (1981) Scaffolding Safety (1987) Seat Belts (1989) Static Electricity, Technical and Safety Aspects (1988) The Secondary Use of Containers (1978) leaflet Tripod-BETA (Incident Analysis EP 95-0321, to be ordered through Library, Library, Rijswijk SIEP-EPT-CSG) Unsafe Act Auditing (1987) The Use of Small Marine Craft by Group Companies (1992) Welding and Cutting (1976) Environmental Guidelines Guide for the Risk-Based Management of Potentially Contaminated Land (2000) Recommendations for Alternatives to Fire Fighting Halons (1994) Safe Handling and Disposal of PCBs (1985) Technical Guide for the Investigation of Potentially Contaminated Land (2004) Technical Guidance for Environmental Assessment (2000) Volatile Organic Compounds (1996) Waste Management Guide (1996)
These publications can be ordered from SI The Hague; PXE Division via E-mail: GUIDES, Internet address: Guides-Yellow@shell.com
September 2004
H S & E Publications Issued under the Auspices of the Shell HSE Committee/HSE Advisers Panel
EP Global Graphics, Rijswijk, Netherlands P03821

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Confined Space Entry

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Confined Space Entry

Policy and strategic objectives

Hazards and Effects Management

Planning and procedures

Corrective action and improvement

Corrective action and improvement

Health, Safety and Environment

Shell Health, Safety and Environment Panel

Confined Space Entry

Confined Space Entry, Issue 2.0, September 2004

Confined Space Entry, Issue 2.0, September 2004 d

Confined Space Entry, Issue 2.0, September 2004

Confined Space Entry, Issue 2.0, September 2004

1 Purpose and Scope

Purpose and Scope

Confined Space Entry, Issue 2.0, September 2004

2 Scope and Application

Scope and Application

Confined Space Entry, Issue 2.0, September 2004

3 Group Standards and Requirements

Group Standards and Requirements

Confined Space Entry, Issue 2.0, September 2004

Responsibilities and Competence

Confined Space Entry, Issue 2.0, September 2004

Planning, Procedures and HEMP

Confined Space Entry, Issue 2.0, September 2004

Confined Space Entry, Issue 2.0, September 2004

Monitoring and Audit

Confined Space Entry, Issue 2.0, September 2004

Confined Space Entry, Issue 2.0, September 2004

5 Confined Space Hazards

Confined Space Hazards

Confined Space Entry, Issue 2.0, September 2004

5 Confined Space Hazards

Fire and Explosion

Confined Space Entry, Issue 2.0, September 2004

5 Confined Space Hazards

Confined Space Entry, Issue 2.0, September 2004

5 Confined Space Hazards

Hazardous liquids such as benzene, polycyclic aromatics, lead/anti-knock compounds, hydrazine

Confined Space Entry, Issue 2.0, September 2004

5 Confined Space Hazards

Confined Space Entry, Issue 2.0, September 2004

5 Confined Space Hazards

Confined Space Entry, Issue 2.0, September 2004

6 Controls that Apply to all Confined Space Entries

Controls that Apply to all Confined Space Entries

Confined Space Entry, Issue 2.0, September 2004

6 Controls that Apply to all Confined Space Entries

Electrical/Hydraulic Lock-out and Tag-out

Clearance of Process Materials

Confined Space Entry, Issue 2.0, September 2004

6 Controls that Apply to all Confined Space Entries

Testing and Monitoring

Confined Space Entry, Issue 2.0, September 2004

6 Controls that Apply to all Confined Space Entries

Testing equipment should be:

Control of Ignition Sources

Confined Space Entry, Issue 2.0, September 2004

6 Controls that Apply to all Confined Space Entries

Control of Radiation Sources

Lighting and Electrical Equipment and Tools

Internal Combustion Engines and Gas Cylinders

Confined Space Entry, Issue 2.0, September 2004