Management System
Manual
MANUAL #
BOOK COPY
FILE COPY
Michel Moreno
CEO
January 2010
Page: 1 of 6
Original: 01/01/2003
Revised: 01/01/2008
B1.1
SH&E
incidents
to
the
Organization
and
other
B1.2
B1.3
B1.4
Coordinating the facility and site first aid, medical and industrial hygiene
programs.
Maintaining and analyzing incident reports, injury and illness statistical data
and results of SH&E audits / inspections or observations.
Coordinating educational activities on SH&E for all management, supervisory
personnel and employees.
Conducting activities for stimulating and maintaining employee interest in the
SH&E program.
Serving on the safety, health and environmental committee (if applicable).
Reviewing and approving incident investigation reports.
Directing and monitoring a program of supervisory SH&E inspections and
audits.
Keeping informed on applicable governmental SH&E standards and codes.
Providing education, measurements, support and participation in the
Behavioral Safety Process.
Maintain communication with Management concerning SH&E performance
and/or issues.
B1.5
B1.6
Page: 1 of 11
Original: 01/01/2003
Revised: 09/01/2009
Periodically SH&E Department will visit Jobsites. During this visit the SH&E
personnel will perform a project assessment using the Moreno Group LLC and
Subsidiaries Jobsite Hazard Assessment Checklist. (See Attachment 7)
Prior to any Offshore Tool House being sent offshore, an Offshore Tool House
Checklist will be completed. A copy of this checklist will be sent offshore so the
receiving superintendent can review the checklist. (See Attachment 8)
During long duration jobs, the offshore superintendent will periodically inspect their
Offshore Tool House utilizing the Offshore Tool House Checklist.
Any unsatisfactory conditions that the supervisor is unable to correct will require a
work order to be issued. A copy of the signed and dated checklist along with any job
orders shall be forwarded to the Safety, Health and Environmental Department.
Additional inspections shall be required under the following circumstances:
Whenever new substances, processes, procedures, or equipment
are introduced into the work place that represent a new
occupational safety and health hazard.
Whenever the supervisor is made aware of a new or previously
unrecognized hazard.
As a part of an incident investigation.
Note: For equipment inspection requirements refer to specific program.
All inspections, findings and recommendations shall be communicated to the
employees at their Daily Safety Meeting.
Annually Safety, Health and Environmental Department and Management
will conduct an audit of the Moreno Group LLC and Subsidiaries Safety,
Health and Environment Management Systems.
At a minimum the following SH&E programs shall be evaluated during the
annual audit:
Confined Space Entry Program
Energy Isolation Procedure (Lockout/Tagout)
Respiratory Protection Program
Stormwater Prevention Plan
All checklists shall be maintained for a minimum of 3 years
C1.3
Attachment 1
C1.4
Legend:
Safe Check Mark
No X
NA - NA
A
A1
A2
A3
A4
A5
A7
A8
(1)
(2)
(3)
(4)
(5)
(6)
(4)
(5)
(6)
REMARKS:
B
B1
B2
B3
B4
B5
HOUSEKEEPING
(1)
(2)
(3)
REMARKS:
C1.4.a.1
C
C1
C2
C3
C4
C5
FACILITY SIGNS
(1)
(2)
(3)
(4)
(5)
(6)
(4)
(5)
(6)
(4)
(5)
(6)
REMARKS:
D
D1
D2
D3
D4
FIRE PROTECTION
D6
D8
D9
(2)
(3)
D5
D7
(1)
REMARKS:
ELECTRICAL
E1
E2
C1.4.a.2
(1)
(2)
(3)
E
E3
E4
E5
E6
E7
E8
E9
E10
ELECTRICAL (continued)
(1)
(2)
(3)
(4)
(5)
(6)
(4)
(5)
(6)
REMARKS:
WELDING EQUIPMENT
F3
F4
F5
F6
F1
F2
F7
F8
F9
F10
(1)
(2)
(3)
REMARKS:
C1.4.a.3
G1
G2
G3
G4
G5
G6
G7
G8
G9
G10
G11
G12
G13
G14
G15
(1)
(2)
(3)
(4)
(5)
(6)
(4)
(5)
(6)
REMARKS:
H
H1
H2
H3
H4
EMERGENCY RESPONSE
(2)
REMARKS:
C1.4.a.4
(1)
(3)
Offices
I1
I2
I3
I4
I5
I6
I7
I8
(1)
(2)
(3)
(4)
(5)
(6)
___________Reading
REMARKS:
PORTABLE LADDERS
J1
J2
J3
J4
J5
J6
(1)
(2)
(3)
(4)
(5)
(6)
(4)
(5)
(6)
REMARKS:
CHECKLISTS
K1
K2
K3
K4
K5
(1)
(2)
(3)
REMARKS:
C1.4.a.5
L
L1
L2
L3
L4
(1)
(2)
(3)
(4)
(5)
(6)
REMARKS:
SCAFFOLDING
M1
M2
M3
M4
M5
M6
M7
REMARKS:
C1.4.a.6
SAFE
AT
N/A
RISK
Environmental
EA
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
REMARKS:
EB
EB1
EB2
EB3
EB4
EB5
EB6
EB7
REMARKS:
EC
EC1
REMARKS:
C1.4.a.7
ED
ED1
ED2
ED3
ED4
ED5
ED6
ED7
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
REMARKS:
EE
EE1
EE2
REMARKS:
EF
EF1
EF2
EF3
EF4
EF5
EF6
EF7
REMARKS:
C1.4.a.8
EG
EG1
EG2
EG3
EG4
EG5
EG6
EG7
EG8
EG9
SAFE
AT
RISK
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
N/A
REMARKS:
EH
EH1
EH2
EH3
EH4
EH5
REMARKS:
EI
EI1
EI2
EI3
EI4
C1.4.a.9
EI
EI5
EI6
EI7
EI8
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
REMARKS:
EJ
EJ1
EJ2
EJ3
REMARKS:
EK
EK1
FABRICATION SHOP
Is there evidence of spills, leaks, welding waste, floor sweepings,
grinding waste, etc. on the ground surrounding the shop?
REMARKS:
C1.4.a.10
Attachment 2
C1.5
INSPECTION TEAM:
A
A1
A2
A3
A4
A5
A6
A7
A8
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
REMARKS:
B
B1
B2
B3
B4
B5
HOUSEKEEPING
Yard and shop clean and free of debris?
Are areas free of material spills and are dip pans clean?
Adequate room to maneuver mobile equipment?
Trash (metal and waste) cans dumped regularly?
All material stacked securely?
REMARKS:
C1.5.a.1
HAZARD COMMUNICATION
C1
Material Safety Data Sheets (MSDS) and index accessible for all
on-site chemicals?
C2
C3
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
REMARKS:
FIRE PROTECTION
D1
D2
D3
D4
D5
D6
D7
D8
D9
REMARKS:
E
E1
E2
E3
E4
E5
E6
E7
E8
E9
E10
C1.5.a.2
ELECTRICAL
Are lights operational?
Is the conduit in good condition and all wiring in conduit?
Are all electrical control panels labeled as to function and voltage?
Area in front of circuit breakers clear 36 inches?
Are electrical outlets not overloaded?
Are outlets in good condition?
Are cords on electrical tools in good condition?
Are all 3-prong extension cords in good condition? (i.e. no tape,
cuts, burns, etc.)
Are ground fault circuit interrupters (GFCI) provided on all
temporary electrical equipment?
Are portable electrical tools and cords inspected and issued with
proper color tag for the month?
REMARKS:
WELDING EQUIPMENT
F3
F4
F5
F6
F1
F2
F7
F8
F9
F10
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
REMARKS:
G
G1
G2
G3
G4
G5
G6
G7
G8
C1.5.a.3
G9
G10
G11
G12
G13
G14
G15
SAFE
AT
N/A
RISK
SAFE
AT
RISK
REMARKS:
H1
H2
H3
H4
H5
H6
H7
REMARKS:
C1.5.a.4
N/A
I
I1
I2
I3
I4
I5
I6
PORTABLE LADDERS
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
REMARKS:
J
J1
J2
J3
J4
REMARKS:
SCAFFOLDING
K
K1
K2
K3
K4
K5
K6
K7
REMARKS:
C1.5.a.5
SAFE AT RISK
L1
RFSI
L2
RFSI
L3
RFSI
L4
RFSI
L5
RFSI
L6
RFSI
L7
RFSI
L8
RFSI
L9
Has the hook been opened more than 15% of normal throat
opening measured at the narrowest point?
RFSI
L10
Is the hook twisted more than 10 degrees from the plane of the
unbent hook?
RFSI
L11
RFSI
L12
RFSI
L13
RFSI
L14
RFSI
L15
RFSI
L16
RFSI
L17
L18
L19
L20
REMARKS:
C1.5.a.6
RFSI
N/A
M
Chain
size,
inches
13
3/8
19
25
5/8
31
19
7/8
13
1 1/8
1
1 3/8
29
1 3/4
64
64
64
64
32
OK
REMOVE FROM
SERVICE
4 5 64
16
32
1 3 32
13
16
13
1 32
Is hook cracked?
M3
M5
Has the hook been opened more than 15% of the normal
throat opening measured at the narrowest point?
Has the hook been twisted more than 10 degrees from
the plane of the unbent hook?
Is the safety latch in working condition?
M6
M7
M4
___________
___________
___________
______
SAFE
AT RISK
C1.5.a.7
Attachment 3
C1.6
A
A1
A2
A3
SAFE
AT
RISK
N/A
SAFE
AT
RISK
N/A
A4
A5
Are open holes identified and barricaded with 3/8 wire rope and
hurricane fencing?
A6
A7
REMARKS:
B
B1
B2
B3
B4
B5
HOUSEKEEPING
Are work areas clean and free of debris?
Are work areas free of material spills and are dip pans clean?
Adequate room to maneuver?
Trash (metal and waste) cans dumped regularly?
All material stacked securely?
REMARKS:
C1.6.a.1
FIRE PROTECTION
C1
C2
C3
C4
C5
C6
C7
C8
C9
C10
C11
SAFE
AT
N/A
RISK
REMARKS:
LOCKOUT / TAGOUT
D
D1
D2
D3
D4
D5
REMARKS:
C1.6.a.2
SAFE
AT
RISK
N/A
ELECTRICAL
E
E1
E2
E3
SAFE
AT
RISK
N/A
REMARKS:
WELDING EQUIPMENT
F
F1
F2
F3
F4
F5
F6
F7
F8
F9
SAFE
AT N/A
RISK
F10
F11
F12
REMARKS:
C1.6.a.3
G1
G2
G3
G4
G5
G6
G7
G8
G9
G10
SAFE
AT
RISK
N/A
SAFE
AT
RISK
N/A
REMARKS:
H
H1
H2
H3
H4
H5
H6
H7
H8
H9
H10
H11
H12
H13
C1.6.a.4
REMARKS:
PORTABLE LADDERS
I
I1
I2
I3
I4
I5
I6
I7
SAFE
AT
N/A
RISK
REMARKS:
J
J1
J2
RIGGING EQUIPMENT
J3
J4
J6
J7
J8
J9
AT
N/A
RISK
J5
SAFE
C1.6.a.5
REMARKS:
K
K1
K2
K3
K4
K5
K6
K7
K8
K9
K10
K11
K12
K13
K14
K15
K16
K17
K18
K19
K20
K21
K22
C1.6.a.6
SAFE
AT
N/A
RISK
REMARKS:
PAPERWORK
L
L1
L2
L3
L4
L5
L6
L7
Has the crew been issued a work/hot work permit and is it current?
Is the Behavioral Safety Observation process being used? If so,
are the cards being discussed in the SH&E Meeting and is the
participation at an appropriate level?
Did the Superintendent complete the Short Service Employee
Mentor Form?
Are Short Service Employees identified with a SSE sticker on hard
hats?
Is the Short Service Employees Mentor providing them direction?
Is the Offshore Tool House Checklist being used?
Verify condition of Offshore Tools House (i.e. neat, orderly, tools
tagged out, etc.)?
L9
L11
L12
AT
N/A
RISK
L8
L10
SAFE
REMARKS:
C1.6.a.7
SCAFFOLDING
M1
M2
M3
M4
M5
M6
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
REMARKS:
N
N1
N2
N3
N4
N5
N6
N7
REMARKS:
C1.6.a.8
Attachment 4
C1.7
INSPECTION TEAM:
Supervisor (Leader)
* If SAFE, provide location, remedial action taken and date of action in REMARKS.
** If NO, document in REMARKS.
A
A1
A2
SAFE
AT
RISK
N/A
REMARKS:
B
B1
B2
B3
SAFE
AT
RISK
N/A
B4
B5
B6
REMARKS:
C1.7.a.1
C
C1
C2
C3
C4
C5
SAFE
AT
RISK
N/A
REMARKS:
D1
D2
D3
D4
D5
D6
SAFE
AT
RISK
N/A
SAFE
AT
RISK
N/A
REMARKS:
EMERGENCY EQUIPMENT
E
E1
E2
E3
E4
REMARKS:
C1.7.a.2
F
F1
SAFE
AT
RISK
N/A
REMARKS:
G
G1
G2
G3
G4
G5
SAFE
AT
N/A
RISK
REMARKS:
H
H1
H2
H3
EQUIPMENT
SAFE
AT
RISK
N/A
REMARKS:
C1.7.a.3
Attachment 5
C1.8
INSPECTION TEAM:
A
A1
A2
A3
A4
A5
A6
A7
A8
A9
A10
A11
A12
SAFETY
SAFE
AT
RISK
N/A
Has paint samples been taken to analyze for lead content? *If
paint contains lead refer to Lead Job Safety Checklist
Has deck been grounded prior to work? *If no, deck needs to be
grounded prior to work.
Are there any open holes or missing handrails? *If Safe, all holes
and handrails must be corrected prior to work beginning.
Are there adequate walkways going up on the deck?
Has the deck been checked for NORM content? *If Safe, copy of
NORM free certificate needs to be provided by customer. If no,
deck needs to be checked for NORM.
Has production equipment, pipes and etc. been cleaned and
gassed free prior to any cutting or welding should be performed?
Has deck been checked for hidden hazards such as items hidden
underneath beams and flanges?
Has deck been checked for rusted handrails, stair treads, grating,
and stairway handrails? *Rusted and damaged items need to be
repaired with new grating or steel.
Has production equipment such as skidpans and living quarters
been checked for flammable or explosive material that could catch
fire when hot work is being conducted? *If no, skids and
miscellaneous areas on deck that may contain flammable or
explosive material needs to be cleaned out.
Have lifelines been installed on areas of deck where grating is
being removed during demolition work? *Lifelines need to be
installed on all areas where grating has been removed or there is
potential for a fall.
Has scope of work been communicated to all involved parties?
*Communication between crafts should be established before work
operations begin to prevent injuries from multiple job tasks being
performed.
Have tarps and visqueen been installed on deck for any blasting
operations that may be performed on painted surfaces that contain
lead? *Enclosure of deck is required before blasting begins.
C1.8.a.1
REMARKS:
ENVIRONMENTAL
B1
B2
SAFE
AT
RISK
N/A
SAFE
AT
RISK
N/A
Are there any containers or drip pans with liquids that have the
potential of spilling?
*If Safe, containers and drip pans need to be covered that nothing
can spill until containers are properly disposed of and drip pans
are cleaned?
Are there any unlabeled containers of liquid? *If Safe, Customer,
Facility Manager and SH&E Department needs to be notified so
that containers can be properly disposed of.
REMARKS:
EMERGENCY EQUIPMENT
C
C1
REMARKS:
C1.8.a.2
Attachment 6
C1.9
NO
N/A
PRIOR TO WORKING
Has everyone that will be
working on the job been blood
level lead tested?
Has everyone one that will be
working on the job had
pulmonary function tests?
Has everyone that will be
working on the job been fit
tested for respirators?
SAFE
NO
N/A
SAFE
NO
DURING JOB
Has air monitoring been
performed for all job functions
and around perimeters of the
work area?
Are all employees wearing
proper PPE when working on
the lead surface? (respirators
required anytime lead paint is
disturbed)
N/A
ENVIRONMENT
Has wind breakers been setup
to make sure that lead is not
leaving work area?
Has Decon trailer wastewater
been tested prior to being
disposed of on the ground?
(Until sample has been taken
all waste water from Decon
must be stored in drums until
sample results indicate that
sample is safe to dispose of)
REMARKS:
INSPECTION TEAM:
Date:
C1.9.a.1
Attachment 7
C1.10
A
A1
A2
A3
A4
A5
A6
A7
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
REMARKS:
HOUSEKEEPING
B
B1
B2
B3
B4
B5
REMARKS:
C1.10.a.1
FIRE PROTECTION
C
C1
C2
C3
C4
C5
C6
C7
C8
C9
C10
C11
SAFE
AT
RISK
N/A
SAFE
AT
RISK
N/A
REMARKS:
LOCKOUT / TAGOUT
D
D1
D2
D3
D4
D5
REMARKS:
C1.10.a.2
ELECTRICAL
E
E1
E2
E3
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
REMARKS:
WELDING EQUIPMENT
F
F1
F2
F3
F4
F5
F6
F7
Are mufflers and exposed hot surfaces insulated? (Welding Machines / Air
Compressors)
F8
F9
F10
F11
F12
Is welding machine attached to the platform ESD system? If Safe, has the
nut in the Versa Valve been removed?
F13
REMARKS:
C1.10.a.3
G
G1
G2
G3
G4
G5
Are pneumatic hose safely connected together with safety pins and whip
checks?
G6
G7
Are cutting tools edges sharp so tool will move smoothly without binding
or skipping?
G8
G9
G10
REMARKS:
C1.10.a.4
SAFE
AT
RISK
N/A
H1
Are employees wearing Hard Hats, Safety Glasses, Proper Clothing and
Steel Toed Boots? (i.e. clear safety glasses at night)
H2
H3
H4
H5
H6
Are employees using fall protection properly (i.e. anchor devices, 100%
tied off, etc.)?
H7
H8
H9
H10
H11
H12
SAFE
AT
N/A
RISK
SAFE
AT
N/A
RISK
H13
H14
H15
H15
REMARKS:
PORTABLE LADDERS
I
I1
I2
I3
I4
I5
I6
I7
REMARKS:
C1.10.a.5
RIGGING EQUIPMENT
J
J1
J2
J3
Are chain or wire rope slings being used tagged and meets API RP
2d requirements? (i.e. kinking, broken wires, distortion, heat
damage, dent hooks, bad end attachments, metal corrosion or
metal loss)
J4
J5
J6
J7
J8
J9
SAFE
AT
RISK
N/A
SAFE
AT
RISK
N/A
REMARKS:
K1
Are employees mixing paint wearing proper PPE (Long sleeves, Apron,
Safety Glasses, Faceshield, Rubber Gloves, and mask OV
Respirator)?
K2
K3
K4
K5
K6
K7
K8
K9
Do all paint cans, solvent cans and waste drums have covers in place
when not being emptied or filled?
K10
K11
C1.10.a.6
K12
Are On/Off safety valves on air line hoses and are they in arms reach of
blast nozzle?
K13
Are On/Off safety valves turned off when blast nozzle is not in use?
K14
Are pressure gauges on paint pots in good condition and readable (i.e.
not covered with paint)?
K15
K16
K17
Is the air spider frame in good condition? (i.e. not bent, etc.)
K18
Are air spiders being utilized properly (proper tie-off, proper anchor point
for spider and employee)?
K19
Is the air spider oil level within the oil lubricator adequate?
K20
Is the correct transfer cable being utilized on all spiders with certification
tag (i.e. transfer chain, certified transfer cable)?
K21
K22
K23
K24
REMARKS:
L
L1
L2
L3
L4
L5
L6
L7
L8
L9
L10
L11
L12
PAPERWORK
SAFE
AT
N/A
RISK
REMARKS:
SCAFFOLDING
M
M1
M2
M3
M4
M5
M6
SAFE
AT
RISK
N/A
REMARKS:
N1
N2
N3
N4
N5
N6
N7
REMARKS:
C1.10.a.8
SAFE
AT
N/A
RISK
O
O1
O2
O3
O4
O5
O6
SAFE
AT
RISK
N/A
Header Information:
Was all header information provided?
Sequence of basic job steps:
Are the job steps defined at an appropriate level of detail?
Is a pre-job safety meeting included?
Is a site inspection included?
Have any SSE been identified?
Potential Accidents or hazards:
Have potential accidents and hazards been identified?
Do they appear to be job-specific?
Was a checklist on back of the JSEA used to help identify hazards?
Recommended Safe Job Procedure:
Do job procedures appear to be job-specific?
Are job procedures clear and at appropriate level of detail?
Do procedures cover entire job from pre-job to post-job
requirements?
Have mentors been assigned to any SSE personnel?
Are Responsible Parties identified for each step?
Were lockout/tagout requirements identified?
Were barricading requirements identified?
Were communications requirements identified?
PPE Requirements
Have all required PPE been specified on the form?
Have all potential accidents or hazards been addressed either
through safe job procedures, PPE or both?
Other:
Has the JSEA form been signed by all employees involved in the
job?
Was a Crane Lift Plan required? If so, was it prepared?
Were the crew, scope or conditions of the job changed during the
job?
If so, was the JSEA form reviewed, modified, and re-signed as
required?
Is the fall rescue plan on back of JSEA being utilized whenever
employees are using fall protection?
REMARKS:
C1.10.a.9
P
P1
P2
What was your part in the developing of the JSEA, identifying of hazards and
setting Recommended Safe Procedures / Protection?
P3
In addition to the information provided on the JSEA, would you like to see
anything added to the JSEA (i.e. form, JSEA for Task, etc.) If any, what hazards
did you feel were not identified on the JSEA?
P4
P5
What would you do if the conditions changed during your task? (i.e. production
employees started pulling samples from a vessel?)
P6
In identifying the hazards of the task was the checklist on back of the JSEA
utilized? If so, where did you conduct this checklist?
C1.10.a.10
Q
Q1
How was the task JSEA developed and communicated with your personnel?
Q2
Q3
Q4
Q5
If conditions change during a task, what do you expect your employees to do?
Have you communicated your expectations to them?
Q6
In identifying the hazards of the task was the checklist on back of the JSEA
utilized? If so, where did you conduct this checklist?
C1.10.a.11
R
R1
R2
R3
Were the hazards of the job identified and properly addressed? If not, explain.
R4
Were there any observed difficulties implementing the JSEA process? Explain.
R5
Were there any changes in job scope, conditions or personnel? Were they
properly addressed?
R6
R7
C1.10.a.12
S
S1
1.1
1.2
1.3
S2
2.1
2.2
2.3
2.4
2.5
2.6
JSEA SCOREBOARD
1 2 3 4 5
S3
Job Execution:
3.1
3.2
3.3
S4
4.1
4.2
Employee Qualifications:
SSE employees are identified and mentors assigned.
Were the employees able to effectively communicate to you
the scope of their job and JSEA?
C1.10.a.13
Attachment 8
C1.11
INSPECTION TEAM:
A
A1
A2
A3
SAFE
AT
RISK
N/A
Chain Intact?
Latch intact and hook not stretched?
Is chain kinked or Arced?
REMARKS:
GAUGES
AT
N/A
RISK
B2
B3
B1
SAFE
REMARKS:
C1.11.a.1
HAND TOOLS
SAFE
AT
RISK
N/A
C1
C2
C3
C4
C5
C6
C7
C8
C9
REMARKS:
D
D1
D2
D3
D4
D5
D6
D7
SAFE
AT
RISK
NA
REMARKS:
EXTENSION CORDS
E1
E2
E3
E4
E5
C1.11.a.2
SAFE
A
RISK
N/A
REMARKS:
F1
F2
F3
F4
F5
F6
F7
SAFE
AT
RISK
N/A
REMARKS:
G1
G2
G3
G4
SAFE
AT
RISK
N/A
REMARKS:
I
I1
I2
I3
I4
PERSONAL PROTECTIVE
EQUIPMENT
SAFE
AT
RISK
N/A
PERSONAL PROTECTIVE
EQUIPMENT (continued)
SAFE
AT
RISK
N/A
I5
I6
I7
I8
I9
I10
REMARKS:
SHACKLES
K
K1
K2
K3
K4
SAFE
AT
RISK
N/A
REMARKS:
L
L1
L2
L3
L4
C1.11.a.4
SAFE
AT
RISK
N/A
REMARKS:
LOCKOUT / TAGOUT
M
M1
M2
M3
M4
SAFE
AT
RISK
N/A
REMARKS:
N1
N2
N3
N4
N5
N6
N7
N8
N9
N10
N11
N12
REMARKS:
BEAM CLAMPS
O
O1
SAFE
AT
RISK
N/A
REMARKS:
C1.11.a.5
P1
P2
P3
P4
P5
P6
SAFE
AT
RISK
N/A
REMARKS:
Q1
Q2
Q3
Q4
Is there evidence that the cable on the air spider has been
arched?
Q5
Q6
Q7
Q8
SAFE
AT
RISK
N/A
REMARKS:
R
R1
R2
R3
R4
R5
REMARKS:
C1.11.a.6
SAFE
AT
RISK
N/A
Superintendent Approval
Print Name:
Signature:
Date:
NOTE: Fax back to offshore manager after approval.
C1.11.a.7
INSPECTION TEAM:
SAFE
AT
N/A
RISK
A1
A2
A3
A4
Chain Intact?
Latch intact and hook not stretched?
Wire Not Damaged?
Are there 10 randomly broken wires in one rope lay?
Are there 5 broken wires in one strand in one lay?
Is there kinking, gouging, bird caging or other damage?
Is there evidence of corrosion or heat damage?
Is chain kinked or Arced?
REMARKS:
PIPE JACKS
B
B1
B2
B3
B4
B5
SAFE
AT
N/A
RISK
REMARKS:
C1.11.b.1
HAND TOOLS
C
C1
C2
C3
C4
AT
RISK
N/A
SAFE
AT
RISK
N/A
C5
C6
C7
C8
C9
SAFE
REMARKS:
D
D1
D2
D3
D4
D5
D6
D7
REMARKS:
C1.11.b.2
E
E1
E2
E3
E4
E5
SAFE
AT
RISK
N/A
REMARKS:
WELDING EQUIPMENT
F
F1
F2
F3
F4
F5
F6
F7
F8
SAFE
AT
RISK
N/A
REMARKS:
G1
G2
G3
G4
SAFE
AT
RISK
N/A
C1.11.b.3
REMARKS:
GAUGES
H
H1
H2
H3
H4
H5
SAFE
AT
RISK
N/A
REMARKS:
PERSONAL PROTECTIVE
EQUIPMENT
I
I1
I2
I3
I4
I5
I6
I7
I8
I9
REMARKS:
C1.11.b.4
SAFE
AT
RISK
N/A
TORCHES
J
J1
J2
J3
J4
J5
SAFE
AT
RISK
N/A
REMARKS:
K
K1
K2
K3
K4
SHACKLES
SAFE
AT
RISK
N/A
a.
Is the cotter pin present?
Is the capacity of the shackle indicated?
Is the shackle in good condition?
Are shackles Crosby or equivalent? If no, take out of service
and replace with Crosby or equivalent.
REMARKS:
L
L1
L2
L3
L4
SAFE
AT
RISK
N/A
b.
Is the first aid kit an USCG Approved First
Aid Kit?
c.
Is the kit in good condition?
d.
Is there a Bloodborne Pathogens kit
available?
e.
Is the kit full?
REMARKS:
C1.11.b.5
M1
M2
M3
M4
M5
M6
M7
M8
M9
Has the hook been opened more than 15% of normal throat
opening measured at the narrowest point?
M10
Is the hook twisted more than 10 degrees from the plane of the
unbent hook?
M11
M12
M13
M14
M15
M16
M17
REMARKS:
C1.11.b.6
SAFE
AT
RISK
N/A
N
N1
N2
N3
N4
LOCKOUT / TAGOUT
SAFE
AT
RISK
N/A
REMARKS:
O
O1
BEAM CLAMPS
SAFE
AT
RISK
N/A
REMARKS:
P1
P2
P3
P4
P5
P6
SAFE
AT
RISK
N/A
REMARKS:
Q1
Q2
Q3
Q4
Is there evidence that the cable on the air spider has been
arched?
Q5
Q6
Q7
Q8
C1.11.b.7
REMARKS:
R1
R2
R3
R4
R5
REMARKS:
C1.11.b.8
SAFE
NO
N/A
Superintendent Approval
Print Name:
Signature:
Date:
NOTE: Fax back to offshore manager after approval
C1.11.b.9
Page: 1 of 2
Original: 01/01/2003
Revised: 01/01/2008
C2.1
C2.2
Page: 1 of 13
Original: 01/01/2003
Revised: 5/01/2009
D1.1
Qualification
Pre-qualification
Safety, Health and Environmental performance are important parameters in the
Contractor selection process. The pre-qualification process consists of the review of
the Contractors SH&E statistical performance.
Statistical Performance
To initiate an evaluation of a prospective Contractors safety, health and
environmental performance, Moreno Group LLC and Subsidiaries will request that all
Contractors complete a Generic Safety, Health and Environmental Questionnaire
(see Attachment 1).
The questionnaire is designed to collect relevant information on historical safety,
health and environmental performance. The acquired information will be utilized to
compare the prospective Contractors performance to that of other Contractors within
the similar work classifications.
Pre-qualification criteria information
The following selection criteria will be utilized for this initial pre-qualification stage:
Experience Modification Rate (EMR) for the past three years (NCCI rate)
Total recordable incident rates for injuries and illnesses for the past three years
for the business unit or region that the Contractor is operates from;
Number of fatalities experienced in the past three years for the business unit or
region that the Contractor operates from; and
Number of regulatory/legal citations, penalties and/or sanctions issued against
the Contractor within the past three years for the business unit or region that the
Contractor operates from.
Pre-qualification performance cut-off
Current EMR should not exceed 1.00, or the previous three-year average should
not exceed 1.25
And
The average of the last two of the previous three years total recordable incident
rate should not exceed the most current national BLS rate for the corresponding
businesses.
If the Contractor fails to qualify within the above restrictions, the Contractor
qualification process will be terminated until such a time that the Contractor meets
with Moreno Group LLC and Subsidiaries and provide sufficient information to
D1.3
D1.4
< 1.0
>1- 1.25
+15
+10
Site Assessment
Maximum
+15
SH&E Mgmt.
Process
Assessment
Maximum
+45
Fatality
- 15
- 10
-5
D1.8
Attachment 1
D1.9
Date: ______________________________
__________________________________
Contact: ____________________________
__________________________________
__________________________________
Phone #: ___________________________
__________________________________
Fax #: _____________________________
__________________________________
SIC # _____________________________
Please describe the area or region this questionnaire applies (i.e. local Division,
District, Branch).
2.
In the table below, provide the three most recent full years of incident information for
your company. See "Attachment 1, Definition of Terms" for details.
In addition to completing the tables, attach copies of your company's OSHA 300
log for the last three full years. If your company is not required to complete an
OSHA 300 log, provide copies of other appropriate industry-related
documentation, e.g. ADC, etc. We require verification of the EMR/discount rate
information, see "Attachment 1" for details.
Exposure
Incidence Number of
Average
Number of
or
Rate of
Lost
Year Number of
Recordable
Employee
Recordable Workday
Employees
Cases
Hours
Cases
Cases
Incidence
Rate of
Lost
Workday
Cases
Number of
Lost
Severity
Workdays
Rate
EMR
Number of
Fatalities
3.
Specify the basis for exposure or employee hours (8 hr shifts, 12 hr shifts, 24 hrs, etc.)
4.
D1.9.a.1
5.
Has your company received any inspections from a regulatory agency during the last
three years?
Yes____ No____
If yes, please provide details: ____________________________________________
___________________________________________________________________
6.
Has your company received any citations from a regulatory agency during the last
three years?
Yes____ No____
If yes, please provide details: ____________________________________________
___________________________________________________________________
7.
8.
Please respond to ALL items with "Yes ,No, or N.A." Do not leave any items
unanswered. (Estimated Percentage of Employees should reflect the percentage of
employees who are required to have the training - not the percentage of the total
number of employees in your organization):
PROGRAMS/TRAINING
Reference
Source
Program
Documented
and Written
Yes/No/NA
API T-1
API RP T-1
Bloodborne Pathogens
OSHA 29 CFR
1910.1030(g)(2)
OSHA 29 CFR
1910.146(g)
see above
see above
see above
Cranes
API RP 2D
Defensive Driving
OSHA Proposed
DOT 49 CFR
172.704
Drug Awareness
DOT 46 CFR
16.401 & 391.119
D1.9.a.2
Estimated
Percentage of
Employees
Receiving
Training
Frequency of
Training for
Individual
Employees
Individual
Employee
Training
Documented
Yes/No/NA
PROGRAMS/TRAINING
Reference
Source
Program
Documented
and Written
Yes/No/NA
Electrical Safety
OSHA 29 CFR
1910.332
Emergency Response
OSHA 29 CFR
1910.38(a)
First Aid/CPR
OSHA 29 CFR
1910.151(b)
Forklifts
OSHA 29 CFR
1910.178(l)
OSHA 29 CFR
1910.119(h)(3)
H2S
MMS 30 CFR
250.67
HAZCOM
OSHA 29 CFR
1910.1200(h)
OSHA 29 CFR
1910.120
Hazwoper 8 Hour
see above
Hazwoper 24 Hour
see above
Hazwoper - 40 Hour
see above
see above
Hearing Conservation
OSHA 29 CFR
1910.95
OSHA 29 CFR
1910.157(g)
Lead Worker
OSHA 29 CFR
1926.62(l)
Lead Supervisor
see above
Lockout/Tagout - Authorized
Person
OSHA 29 CFR
1910.147(c)(7)
Lockout/Tagout -Affected
Person
see above
Lockout/Tagout - Other
see above
OSHA 29 CFR
1910.132(f)
OSHA 29 CFR
1910.119(g)(1)
MMS 30 CFR
250.214
Respiratory Protection
Estimated
Percentage of
Employees
Receiving
Training
Frequency of
Training for
Individual
Employees
Individual
Employee
Training
Documented
Yes/No/NA
OSHA 29 CFR
1910.134(e)(5)
OSHA 29 CFR
1910.252(a)(2)(xii)
(c)
MMS 30 CFR
250.52
D1.9.a.3
PROGRAMS/TRAINING
Reference
Source
Program
Documented
and Written
Yes/No/NA
Well
Control/Completion/Workover
MMS 30 CFR
250.212-213
N/A
Rigging/Material Handling
N/A
Supervisory Skills
N/A
Survival Craft
N/A
N/A
N/A
N/A
N/A
Estimated
Percentage of
Employees
Receiving
Training
Frequency of
Training for
Individual
Employees
Individual
Employee
Training
Documented
Yes/No/NA
9.
10.
Does your company comply with the Process Safety Management provisions found in
29 CFR 1910.119 and/or API RP 75?
Yes____ No____
Comments: __________________________________________________________
___________________________________________________________________
11.
12.
13.
14.
Yes____ No____
15.
What were the topics or issues discussed at the last two safety meetings?
Topics/Issues:
Meeting Date:________________________
Topic/Issues:
Meeting Date:________________________
D1.9.a.4
16.
17.
Yes____ No____
18.
Yes____ No____
19.
20.
COMPANY
PROVIDED
COMPANY
REQUIRED
Hard hats(ANSI-Z89.1)
(29 CFR 1910.135)
NA___
Yes___No___
Yes___No___
Safety shoes(ANSI-Z41.1)
(29 CFR 1910.136)
NA___
Yes___No___
Yes___No___
Eye protection(ANSI-Z87.1)
(29 CFR 1910.133)
NA___
Yes___No___
Yes___No___
Hand protection
(29 CFR 1910.132)
NA___
Yes___No___
Yes___No___
Hearing protection
(29 CFR 1910.95)
NA___
Yes___No___
Yes___No___
Fall protection
(29 CFR 1910.129)
NA___
Yes___No___
Yes___No___
Respiratory protection
(29 CFR 1910.134)
NA___
Yes___No___
Yes___No___
NA___
Yes___No___
Yes___No___
In addition to regulatory required the Personal Protective Equipment , what other PPE
is required or supplied? _______________________________________________
___________________________________________________________________
D1.9.a.5
21.
22.
Does your company have a written policy regarding drug screening or testing of your
employees?
Yes____ No____ Comments: ___________________________________________
___________________________________________________________________
23.
If yes, which set of DOT regulations is your drug testing program designed to satisfy?
24.
Yes____ No____
Yes____ No____
Yes____ No____
Yes____ No____
Yes____ No____
25.
( ) Probable Cause
( ) Post Accident
( ) Periodic
Other:
Does your company have policy requiring written accidents/incident reports (spills,
injuries, property damage, etc.)?
Yes____ No____
26.
Yes____ No____
27.
Does your company document, investigate, and discuss near miss accidents?
Yes____ No____
If yes, is documentation available?
D1.9.a.6
Yes____ No____
28.
29.
Yes____ No____
30.
31.
Does your company verify that subcontractors meet or exceed your safety and training
requirements?
Yes____ No____
If no, explain: ________________________________________________________
___________________________________________________________________
32.
Describe the programs utilized to monitor the safety performance of your company to
determine progress (for example, management meetings, safety committee/team,
statistical reports, etc.):
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
33.
Does your company have a safety manual with a clearly written safety policy
endorsed by upper management?
Yes____ No____ Comments: ___________________________________________
34.
Yes____ No____
Who reviews the safety audit/review and how often? Job Title:
Comments: ________________________________________________________
36.
Does your company involve its employees in health, safety, and environmental
awareness programs?
Yes____ No____
If yes, describe how they are involved: ____________________________________
D1.9.a.7
37.
Who in your company is responsible for coordinating your health, safety and
environmental program? Job Title:
Is safety a full time responsibility for this position?
Yes____ No____
39.
Yes____ No____
Is your company required to have any Federal, state, or local licenses or permits to
perform your service(s) (for example, NORM, asbestos, DOT, etc.)?
Yes____ No____
List types of licenses/permits and state of issue:
__________________________________________________________________
Having completed this survey, do you have any additional comments or questions to
discuss?
__________________________________________________________________
__________________________________________________________________
D1.9.a.8
DEFINITION OF TERMS
Year
List the three most recent full calendar years. Specify months, if less than a full
year.
Average Number of Employees
List the average number of employees worked during the year. An employee shall
be defined as any person engaged in activities for an employer from whom direct
payment for services is received. Included are working owners and officers.
Exposure or Employee Hours
List the total number of hours worked during the year by all employees, including
those in operating, production, maintenance, transportation, clerical, administrative,
sales, and other activities.
Number of Recordable Cases
List the total number of recordable cases that occurred during the year. A
recordable case will be defined as any work-related injury case requiring more than
first aid, and all occupational illnesses. Recordable cases include all occupational
illnesses, and all occupational injuries resulting in lost workdays - either days away
from work or days of restricted work activity, medical treatment other than first aid,
loss of consciousness, restriction of work or motion, temporary or permanent
transfer, or the termination of an injured or ill employee.
Incidence Rate of Recordable Cases
D1.9.a.9
D1.9.a.10
Attachment 2
D1.10
Acceptable
Needs Improvement
Not Acceptable
SH&E Plan
SH&E Staff
SH&E Work Procedures
Substance Abuse & Contraband
Audits & Inspections
Employee Training
New Hires
Continuous
Management
Records Management
Hazard Control
Emergency Preparedness
Sub-Contractors
N/A
SH&E Manual
Incident Reporting & Investigation
SH&E Meetings
Acceptable Components: ________ X 3 =
_______
Needs Improvement
_______
________ X 1 =
Total Score
D1.10.a.1
Attachment 3
D1.11
Acceptable
Needs
Improvement
Not
Acceptable
N/A
HOUSEKEEPING
Are aisles clear and unobstructed?
Are waste containers emptied?
Are work areas clean and organized?
Are work areas adequately illuminated?
D1.11.a.1
Acceptable
Needs
Improvement
Not
Acceptable
N/A
WORK PRACTICES
Are employees working in a safe manner?
Are employees obeying posted warning signs?
Did the company conduct a pre-job meeting?
Are items properly locked and tagged?
Are work permits completely filled out?
Are work permits posted?
Are containers properly labeled?
Are MSDS readily available?
Is material handing equipment being
properly operated?
Is material handling equipment being
inspected?
Is machinery adequately guarded?
Is adequate fire protection
equipment on location?
Are fall hazards adequately controlled?
Are flammable substances properly stored?
Is spill containment provided for chemical
distribution areas?
Are adequate first aid facilities provided?
_______
_______
D1.11.a.2
Attachment 4
D1.12
Contractor: ________________________________________________________
Incident Rates
_________
EMR
_________
_________
Site Assessment
_________
Sub-total
_________
Deductions
Fatalities
_________
Sub-total
_________
TOTAL SCORE
_________
RATING
Approved
80 - 100
Conditional
60 - 79
Non-Acceptable
< 60
D1.12.a.1
Attachment 5
D1.13
Below are minimal requirements for Moreno Group LLC and Subsidiaries Facilities
D1.13.a.1
Emergency
Preparedness
Page: 1 of 19
Original: 01/01/2001
Revised: 01/01/2010
Emergency Preparedness
Purpose
The purpose of the emergency preparedness plan is to provide methods of
evacuation of Moreno Group LLC and Subsidiaries facilities during emergency
situations.
Scope
To provide minimum requirements for safe evacuation of Moreno Group LLC and
Subsidiaries Facilities for potential emergency situations.
Responsibilities
The Facility / Facility Manager or Designee is responsible for:
Providing the necessary leadership and resources to execute this procedure
Develop, implement and continuously evaluate a Facility / Office Site Specific
Emergency Evaluation Procedure.
Assuring evacuation routes are established and clearly marked
Establishing a head count procedure
The First Line Supervisor or Sub-Contractor is responsible for:
Understanding and complying with their Facilitys Emergence Evacuation Plan.
Overseeing the activities of personnel to ensure emergency reporting and
response procedures are followed.
Conduct a head count of their personnel upon arriving to the designated
assembly area.
Updating and answering their employees questions pertaining to this plan.
The Safety, Health and Environmental Department is responsible for:
Provide assistance to Facility Management and the First Line Supervision in the
development, implementation and continuous improvement of their Site Specific
Emergency Evacuation Plan.
Coordinating and conducting Emergency Preparedness Training.
E1.1
Tropical Storm - A tropical cyclone in which maximum sustained surface winds are
39 mph to 73 mph. Tropical storms are given names. The same names continues if
the circulations happen to strengthen to hurricane intensity.
Requirements
Each Facility / Office Manager shall develop and implement a site specific
Emergency Evaluation Plan for their facility. Attachment 1 contains a generic office
building Emergency Evacuation Plan that may help facilitate in the development of
the Site Specific Plan for Office Buildings.
Prior to the development of any office Site Specific Emergency Evacuation Plan, the
office manager shall ensure our plan does not conflict with the evacuation plan
developed by the building owner and/or Management Company. The plan should
either be posted in the facility or made readily available for the employees to review.
Coordinator of Emergency Action Plan
All Supervisors shall be responsible for updating, answering any questions and
explaining employees responsibilities under this plan.
Decision to Evacuate
In the event of fire, explosion, bomb threats or bad weather it may be necessary to
evacuate the site or an area of the facility. If the need arises, the Facility Manager or
his designee should make the decision. Evacuation should be ordered if a situation
could endanger life or health of the personnel.
Evacuation Alert Procedure
The Facility Manager or his designee who orders the evacuation will make an
announcement over the public address system that the site must be evacuated due
to an emergency situation. If the public address is not working, alert other
occupants by word of mouth and/or by radio. If an area is to evacuate, an
announcement will be made indicating said area is to be evacuated and closed off.
Do not enter that area until the barricades are removed. After the evacuation alert
has been made, the person ordering the evacuation will call the local emergency
agency or 911, if needed.
Evacuation Procedure
Fabrication Yards
Upon hearing the announcement or alarm, all personnel on site will stop whatever
they are doing. All equipment, tools and power sources should be turned OFF before
evacuating facility (provided it is safe to do so). Personnel working in offices will
close office doors, windows, and other doors on the way out and proceed directly to
designate emergency exits. Department managers shall ensure that all occupants in
their area are out of their offices and conference rooms and that their area is
completely vacated. Turn off the lights in each office and close the doors. Notify the
E1.3
Facility Manager that your area is vacated and proceed to evacuate yourself.
Evacuation routes shall be located in strategic locations throughout the facility.
While employees are evacuating, they shall try not to walk through smoke or vapor
clouds. If employees are caught in such a situation, they shall make notice of wind
socks to determine wind direction; they shall then walk at right angles to the wind
direction to exit the cloud and to find an upwind evacuation route. Wind socks are
located at the top of the east and west ends of both fabrication buildings and the top
of the pile rack.
The evacuation route plan will show the evacuation route; emergency exits. After
exiting shops, work areas or buildings, all personnel will exit the site by the nearest
exit. All personnel will meet at Designated Assembly Area for a head count. The
Facility Manager and/or the SH&E department will be the last to evacuate. They will
then proceed to the Designated Assembly Area. After the site has been evacuated,
a decision will be made if further steps must be taken.
If handicapped or disabled personnel are in the group being evacuated, a two-man
team is to be designated by the department manager to assist. The two-man team
and the disabled person shall be the last to evacuate, to avoid the possibility of
being shoved by individuals coming from behind them. The team is to inform the
Facility Manager that the disabled persons are evacuated.
Support Offices within Fabrication Facilities
Upon hearing the announcement or alarm, all personnel will stop whatever they are
doing. Personnel working in buildings will close windows, doors and all doors on the
way out. They will proceed directly to designate emergency exits.
Department managers shall ensure that all occupants in their area are out of their
offices and conference rooms and that their area is completely vacated. Turn off the
lights in each office and close office doors. Notify the Facility Manager that your area
is vacated and proceed to evacuate yourself. Evacuation routes shall be located in
strategic locations throughout the facility.
The evacuation route plan will show the evacuation route, emergency exits and fire
extinguisher locations. After exiting the buildings, all personnel will exit the site to the
appropriate Designated Assembly Area for a headcount.
The Facility Manager and/or designee will be the last to evacuate. They will then go
to the Designated Assembly Area.
If handicapped or disabled personnel are in the group being evacuated, a two-man
team is to be designated by the Facility Manager to assist. The two-man team and
the disabled person should be the last people to evacuate, to avoid the possibility of
being shoved by individuals coming from behind them. The team is to inform the
Facility Manager that the disabled persons are out.
E1.4
All department
Participation in the drills is mandatory for all Facility occupants (whether employees
or visitors).
After the drill has been conducted Facility Management, Supervision and the SH&E
Department shall meet to critique the drill. Minutes of this critique meeting should be
kept and maintained.
Extinguishing Fires
If it is determined that the fire can be controlled with fire extinguishers, another
member of the staff must be alerted of the fire emergency to assist with
extinguishing the fire and to alert the Facility Manager or his designee of the fire
emergency. If the fire cannot be controlled with fire extinguishers, the Local Fire
Department must be called and the site evacuated.
In Case of Fire or Fire Alarm (simple procedure)
Notification
If you see smoke, flames, smell smoke, or hear a fire alarm, immediately call the
Local Fire Department (911).
If you think you smell a peculiar or unfamiliar odor, immediately call the Local Fire
Department (911):
Information to be given to the Fire department:
What is on fire
E1.5
Address
Type of occupancy
Telephone number
Listen to dispatcher; always let dispatcher hang up first.
Emergency procedures if you see smoke, flames or smell something burning:
Isolate fire (close door, if possible)
Call the fire department
Make announcement on PA system
Evacuate
Extinguish fire
Emergency procedures in the event of an alarm only:
Notify fire department
Minimum procedures: proceed to Designated Assembly Area for further
instruction and head count.
Important Things to Know
When the Fire Department arrives, the officer is in charge
Special Instructions for the Mobility Impaired
Individuals having any mobility impairment need to be considered prior to any
need for evacuation. It is necessary for department managers to ensure
assistance is available for any mobility-impaired employee that may require
special assistance in the event of an evacuation. A list of these employees
shall be kept with this plan.
After Hours
If you see smoke, flames, smell smoke, or hear a fire alarm, do the following:
Isolate the fire by closing the door.
Notify the fire department by calling 911.
NEVER assume that someone else has called the Local Fire Department.
Threats
If anything suspicious occurs (such as threatening phone calls), remain calm, and
get as much specific information as possible (i.e. location of bomb or intentions), try
to keep the person on the phone, and notify the Facility Manager immediately. Try
to get as much information from the caller as possible as to the nature and details of
the threat.
E1.6
Keep all written threats, notes on threatening calls or unusual occurrences so that
the Facility Manager can evaluate the threat.
The Facility Manager is to notify the Safety, Health and Environmental Department
for instructions in the event of any threatening calls or situations.
Violent Disturbances
Workplace violence can be of various types and origins. Upon Notification of a
violent act or disturbance, which threatens the facility or employees, the Facility
Manager or designee will immediately, contact local authorities?
Any employee may make this initial notification once that employee is secured in a
safe area.
The following information should be obtained:
Location of disturbance
Number of distracters
Distracters activities
Identification of distracters
The Facility Manager or designee will asses the situation and determine the
appropriate course(s) of action based upon the available information. If necessary,
public address notification of the disturbance will be communicated to all personnel.
Employees are to remain clear of disturbance and should not attempt to resolve the
conflict. Local authorities may be contacted to address appropriate situations.
The Facility Manager or designee shall secure the area of a violent disturbance to
preserve anything that maybe considered evidence and must not allow any items to
be removed or disturbed unless directed by Law Enforcement Authorities.
The Facility Manager or designee should lock down the facility and not allow anyone
to enter the facility without prior approval from the Facility Manager or designee.
The Facility Manger or designee shall also work with authorities to secure any
witness statements.
Be alert to any suspicious personnel, visitors or objects.
Medical Emergencies
Personnel: Call the immediate supervisor and the SH&E Department
Call 911, if an ambulance is needed.
Supervisor: Call your immediate manager to report the injury or illness
E1.7
J. Serio, M.D.
Health South7772A Highway 23
Belle Chasse, La. 70037
(504) 349-6363
Dr. Neil Notaroberto (Eye Doctor)
1939 Hicory Avenue Suite 101
Harahan, La.
(504) 737-3456
Houma, La.
Occupational Medical Services
Dr. Sweeny or Dr. Davis
144 Valhi Lagoon Crossing
Houma, La 70360
(985) 223-0032
E1.8
Lake Charles, La
Business Health Partners
299 B Cities Service Highway
Sulphur, La. 70663
(337)626-1011
Fax : (337) 626-0656
Port Sulphur, La
Plaquemines Medical Center
374 Civic Drive
Port Sulphur, la 70083
(985) 564-3344
Mobile, Al.
Infirmary Health System
Doug Daniel (contact)
305 N. Water Street
Mobile, Al.
(251) 431-5800
Baytown, TX
Bay Coast Medical Ctr.
2610 S Highway 146
Baytown, TX
(281) 420-6100
Bay Coast Medical Ctr.
Corpus Christi, TX
Bay Area-Corpus Christi Med
7101 S Padre Island Dr.
Corpus Christi, TX
(361) 761-1200
E1.9
Heart Hospital
7002 Williams Dr.
Corpus Christi, TX
(361) 761-6800
Emergency Room
2606 Hospital Blvd.
Corpus Christi, TX
(361) 902-4151
Spoh Hospital
600 Elizabeth St.
Corpus Christi, TX
(361) 885-0854
Thomas Moloney
Nueces Occupational Med. Clinic
7406 Up River Road
Corpus Christi, Tx. 78409
(361) 289-2890
(361) 289-2963 (fax)
Galveston, TX
University of Texas Med. Ctr.
301 University Blvd.
Galveston, TX 77555
(800) 335-0065
Houston, TX
Patricia Janki, M.D.
12080 East Freeway
Houston, TX 77029
(713) 330-4325
(713) 330-1910 (fax)
E1.10
Pasadena, TX
Bayshore Medical Ctr.
4000 Spencer Hwy.
Pasadena, TX
(713) 944-6666
International
Cabinda, Angola
Ludmed, Ida.
Rau de Macau
Cabinda, Angola
Phone: +244-2312-24755
Fax: +224-2312-23358
E1.11
Luanda, Angola
Talatona Clinic
Rua S10 Sector Talatona Zona CCB2
proximo ao Belas shopping
Telephone:
923 330 843
Fax: 222 399263
Emergency after Hours: 923 330 845
Ilha Clinic
Rua Murtala Mohamed - Clinica
Sagrada Eperana
Telephone:
923 330 845 / 917 485 834
Fax: 222 309 033
Attn: International SOS Angola, Lda
Port of Spain, Trinidad
Port of Spain General Hospital
Charlotte Street, Port of Spain
Trinidad, West Indies
Telephone: +1 809 623 2951
E1.12
Uyapar Hospital
Jardin Levante, AltaVista Sur
Puerto Ordaz City, Bolivar State,
Venezuela
Phone: 00-58-286-9622072 or
00-58-286-9625159
Hurricane Procedures
Hurricane season is from June through November, with the majority of hurricanes
occurring during August and September. The best defense against storm damage is
alertness and prior preparation. For instructions covering hurricane preparedness
and evacuation procedures, personnel should become familiar with their local
hurricane preparedness plans that are specific to that region, district or area.
Winds (MPH)
> 155
131 -155
111 - 130
96 - 110
74 - 94
Storm Surge
> 18
13 - 18
9 - 12
6 - 8
4 - 5
condition and accessibility of each facility and decisions of Local and/or State
authorities.
Phase IV (Facility Evacuation) - Will go into effect upon orders from the Facility
Manager or designee but can be expected to automatically follow Phase III. It may
be applied to a facility, but not necessarily our entire operations simultaneously.
Phase I (General Hurricane Season Precautions)
During Phase I, all workplace assessments shall be performed per the Audit
and Assessment section of this manual. Deficiencies are to be documented, a
work-order developed and issued to the supervisor to be repaired promptly.
All loose material and equipment on facility are to be properly stored and
maintained in a secure manner.
All junk items to be classified as such and sent for disposal or scrap recycler.
All facilities must verify that they have an ample supply of rope, tarpaulin or
clear, heavy, plastic wrap available.
All Supervisors and Facility Managers are to maintain and keep in their
possession a current list of correct addresses and telephone numbers to
personnel under their authority.
Phase II (Pre-Hurricane Procedure)
Secure all loose material and / or equipment
Make sure all Diesel tanks and filled.
Make sure all Used Oil tanks are pumped out.
Make sure all containment and drip pans are pumped out.
Make sure any Hazardous Waste generated at facility is scheduled for
immediate pick-up by Approved Hazardous Waste Disposal Company (see
Process Specific Waste Management Plan within the Hazardous Control
section of this manual).
Phase III (Securing for Hurricane and Preparing for Evacuation)
Stop all compressors.
Secure all equipment and buildings.
Collect all hand held radios and place in a safe but secure location.
Move all unsecured portable fire extinguishers to tool room.
E1.14
Move all gas cylinders into secured racks or firmly secured to building or
structure.
Move all mobile equipment to safe and secure location of facility. The
Operator shall provide the key to the equipment to their Supervisor.
Lower and secure all booms to aerial lifts, cherry pickers and cranes.
Ensure all paints, solvents, lube oils, etc. are placed within a secured
buildings or containment area.
Ensure all hazardous materials within containment area are properly secured
within containment.
All files on company computers shall be backed up. Back-up tapes shall be
provided to employees Supervisor. The Supervisor shall place the back-up
tapes within a safe and secure location.
Notify Supervisor upon completion of securing operations. Wait for facility
evacuation orders from Facility Manager or designee.
Phase IV (Facility Evacuation)
Notify Supervision to order employees to evacuate facility in an orderly
fashion.
Facility Manager or designee will turn off the electricity to facility and
implement Moreno Group LLC and Subsidiaries Energy Isolation Procedure
(Lockout / Tagout). Electricity should not be turned off until all employees
have left the facility.
Ensure all gates and entrances to facility and buildings are locked.
Returning to Facility after Storm
Facility Manager or designee and SH&E Department will perform an Audit
and Assessment to determine if facility is safe for employees to enter.
Assign facility electrician to evaluate and determine if it is safe to turn on
facility electricity.
Prior to Facility Manager or designee removing their lock and tag on facility
electricity and turning on electricity, the entire facility shall be notified
electricity will be turned on.
Thunder Storm or Tornado Procedures
Lightning can strike as far as 10 miles from the area where it is raining. Thats about
E1.15
the distance you can hear thunder. According to the National Weather Service, if
you can hear thunder, you are within striking distance.
All fabrication facilities utilize Weather Sentry Construction Pro to make
determinations regarding lightning & or severe weather conditions.
In the event lightning is visible or thunder is audible, Weather Sentry will provide
data relevant in making recommendations for the best interest of employee safety.
All facilities will adhere to the following when making a recommendation:
-
Tornadoes most frequently occur in the Midwestern, southern, and central states
between the months of March and September.
Tornado Alert Categories
Tornado Watch - Indicates that the weather conditions could result in a tornado.
Tornado Warning - Indicates that a tornado has been sighted or detected by radar.
Thunder Storm or Tornado Preparation and Evacuation
During a tornado watch, listen to the radio or television for current information.
DO NOT tie up telephone lines by calling the weather bureau, except to report
a tornado.
During a tornado warning, be prepared to take immediate cover for protection.
During a thunder storm remove employees from all structures within facility,
when time allows lay down all aerial lifts, cherry pickers and cranes boom,
turn off mobile equipment and remove yourself from the equipment.
Remain calm. Go to the closest building and remain against an inside wall of
the lowest floor. Remain away from windows and stay inside during the storm.
If the building is occupied during a thunder storm or a tornado is sighted in the
vicinity, stay away from the perimeter of the building and areas where glass is
present.
Leave your office and close the door, proceed to the first floor, stay in the
hallways or rooms with no glass. If the tornado is very close, sit or kneel
down in the hallway or a low laying area within the facility, place your head as
close to your lap as possible and protect your head and neck with your hands
and arms.
E1.16
E1.17
Attachment 1
E1.18
1.0
2.0
3.0
FIRE WARDENS
4.0
5.0
6.0
7.0
8.0
9.0
REFERENCE DATA
E1.18.a.1
1.0
B.
C.
1.0
E1.18.a.2
B.
3.0
FIRE WARDENS
3.1
3.2
Each Fire Warden shall be familiar with the Fire Safety Plan, the
location of exits and the location and how to activate the fire alarm.
3.3
In the event of a fire or fire alarm the Fire Warden (when it can be
done safely), shall:
3.4
3.5
Shall see that all occupants are notified of the fire or fire alarm, and
shall instruct occupants as per the Fire Safety Plan.
3.6
E1.18.a.3
4.0
(WALK)
TO
THE
NEAREST
SAFE
EXIT
E1.18.a.4
Floor
12
11
10
9
8
7
6
5
4
3
2
1
North Tower
Stair "A" Stair "B"
Roof
Roof
Access
Access
South Tower
Stair "C" Stair "D"
No Roof Roof
Access
Access
Outside only
Floor
12
11
10
9
8
7
6
5
4
3
2
1
5.0
FIRST AID
In the event of a first-aid incidence, personnel should IMMEDIATELY notify
their First Line Supervisor and/or Manager. First Aid will be provided as
needed by qualified individuals per our Incident Reporting / Medical Attention
Procedure within our SH&E Management System.
First-Aid and Emergency Response kits are located as indicated in the
Emergency Evacuation Plot Plan.
E1.18.a.5
6.0
B.
C.
7.0
E1.18.a.6
7.2
BOMB THREAT
What is the bomb made of? (Obtain details about its parts)
Try to keep the caller talking. If necessary, pretend difficulty with your
hearing. Try to weave these general questions into the conversation:
What did you say? Im sorry I didnt understand what you said.
How do I know this is not a joke?
What group do you represent?
Why are you doing this?
After the call has been terminated, IMMEDIATELY NOTIFY Company
management personnel and building management personnel. Be prepared to
provide your notes and checklist.
NOTE: It may NOT be best to INFORM other personnel of the threat.
Company management and building management staff will notify the proper
municipal authorities, at which time, an emergency evacuation response
and/or building search may result.
E1.18.a.7
8.0
B.
E1.18.a.8
9.0
Fire Wardens
Fire Warden
Title
Location
Ext.
No.
Alternate Fire
Wardens
Ext.
No.
9.2
E1.18.a.9
9.3
9.4
Ext. No.
Location
E1.18.a.10
Attachment 2
E1.19
Drunk
Excited
Irrational
Righteous
Child
Older Person
Teenager
Mentally Disturbed
Angry
Coherent
Determined
Nervous
Emotional
Incoherent
Laughing
Soft
Raspy
Slow
With a stutter
With a disguised voice
Profane
Foreign (where?_________)
Plans
Operations
Personnel
Car Phone
E1.19.a.1
Employee Participation
Page: 1 of 2
Original: 01/01/2003
Revised:
Employee Participation
Purpose
It is the purpose of the Safety, Health and Environmental Management System to
involve employees in the identifying, evaluating and eliminating safety, health and
environmental hazards and at-risk behaviors in the workplace.
Scope
The scope of this program is to identify those processes that promote employee
involvement within Moreno Group LLC and Subsidiaries Safety, Health and
Environmental Management System.
Responsibilities
The Facility Manager / Offshore Manager or Designee is responsible for:
Reviewing all Incident Reports and Work Group Investigations
Participating in Supplemental Incident Investigations.
Reviewing all Hazard Assessments Checklists (weekly)
Coordinate and Participate in Monthly Management Hazard Assessments
Provide resources to First Line Supervisors so items identified on the Hazard
Assessment Checklist can be corrected.
Attending and participating at all monthly SH&E Management meetings.
Attending and participating in Monthly Supervisor Meetings.
Participating in team-based behavioral safety observations.
The First Line Supervisors / Offshore Superintendent is responsible for:
Coordinating and Conducting Incident Reporting and Work Group Investigations
Perform at least once per week the Hazard Assessment Checklist.
Facilitate the correction of those items identified on Hazard Assessment Checklist.
Conduct a daily SH&E meeting.
F1.1
F1.2
Page: 1 of 5
Original: 01/01/2005
Revised:
Maintain communication
performance.
with
SH&E
Department
concerning
SH&E
their
Supervisor
upon
utilizing
their
Stop
Work
Authority.
Requirements
Intervention Protocol
In general terms, the Stop Work Authority process involves a stop, notify, correct
and resume approach for the resolution of a perceived unsafe work actions or
conditions.
The following steps should be utilized as the framework for employees to initiate
their Stop Work Authority.
Step Protocol Instruction
1
If the supervisor is readily available and the affected person(s) are not in
immediate risk, the Stop Work Authority should be coordinated through
the supervisor. If the supervisor is not readily available or the affected
person(s) are in immediate risk, the Stop Work Authority shall be
initiated directly with those at risk.
Notify all affected personnel and supervision of the Stop Work Authority
issue. If necessary, stop associated work activities, remove person(s)
from the area, stabilize the situation and make the area as safe as
possible.
All parties shall discuss and gain agreement on the Stop Work Authority
issue.
If determined and agreed that the stop work issue is valid, then every
attempt should be made to resolve the issue to all affected persons
satisfaction prior to the commencement of work.
F2.3
10
All Stop Work Authority and associated detail shall be documented and
reported on a Behavioral Safety Observation Card.
Reporting
All Stop Work Authority exercised under the authority of this program shall be
documented on Moreno Group LLC and Subsidiaries Behavioral Safety Observation
Card. The employee will be responsible for checking the Stop Work Authority Used
box on the front of the card. The description of the Stop Work Authority issue and
used shall be written on the back of the observation card within the Safe, Stop
Work or At - Risk Comment section
.
Behavioral Safety Observations shall be reviewed by the First Line Supervisor
during the pre-shift SH&E Meeting. Cards indicating Stop Work Authority shall be
reviewed during this meeting in order to:
Measure participation
Determine quality of interventions and follow-up
Trend common issues and identify opportunities for improvement
Facilitate sharing of learnings
Feed recognition programs.
The SH&E Department will regularly publish details regarding the number of Stop
Work Authority actions reported by location as well as details regarding common
trends and learnings.
F2.4
Follow-up
It is the desired outcome of any Stop Work Authority that the identified safety,
health or environmental concern(s) be addressed to the satisfaction for all involved
individuals prior to the resumption of work. Although most issues can be adequately
resolved in a timely fashion at the job site, occasionally additional investigation and
corrective actions may be required to identify and address root causes.
Stop Work Authority issues that required additional investigation or follow-up will be
handled utilizing existing protocols and procedures for incident investigation and
follow-up.
Recognition
The First Line Supervisor should informally recognize individuals when they exercise
their authority to Stop Work Authority or demonstrate constructive participation in a
Stop Work Authority intervention. This informal recognition need be no more than
an expression of appreciation for a job well. Additionally, formal recognition of
selected examples of Stop Work Authority and those responsible should be made
during regularly scheduled safety meetings.
For those employees, the First Line Supervisor feels has demonstrated excellent
SH&E Participation may nominate them to their Manager for an Above and Beyond
Safety Award.
Training
Training regarding this Stop Work Authority Policy and Program will be conducted
as part of Moreno Group LLC and Subsidiaries New Employee Orientation / SH&E
Training. Additionally, a review of the Stop Work Authority shall be completed as
part of all field location safety briefings and regularly in safety meetings.
Documentation of all training and reviews shall be maintained as per established
procedures.
F2.5
Job Safety
and Environmental Analysis
(JSEA)
Page: 1 of 9
Original: 01/01/2001
Revised: 10/01/2009
G1.1
Recommended Safe Procedure/Protection Section shall identify how the hazards will
be either eliminated or how exposure to the hazard(s) will be minimized.
Job Safety and Environmental Analysis shall be developed daily for tasks
conducted. JSEA preparation is a group activity coordinated by the First Line
Supervisor or Offshore Superintendent. The supervisor will complete the first draft
of the JSEA form. The supervisor or task leader will be responsible for engaging all
employees working on the job in the review process:
reviewing the proposed sequence of job steps,
identifying hazards
determining the necessary safeguards.
assigning responsible individual(s)
The JSEA review meeting shall be held immediately preceding the work, so that the
actual work environment will be known and the JSEA can be used to familiarize the
crew with the job. The completed JSEA form must be reviewed and signed by all
who will work on the job and posted at the jobsite. The job supervisor shall
communicate the JSEA to affected personnel within work area.
Note: At anytime a new task is started or the current tasks condition(s) or
situation(s) change work must STOP and the JSEA must be updated or rewritten.
Monitoring the JSEA Process
Management is accountable for ensuring that periodic audits of the JSEA process
are conducted. Audit findings should be documented and communicated to those
responsible for implementing the process. Improvement actions should be identified
and implemented to address any shortfalls identified in the audit process.
Routine Monitoring
On-site supervisors shall routinely monitor the JSEA process on their jobs. They
should check to see that:
the process is being applied effectively,
safety and environmental hazards are being identified and addressed
the right people are involved in JSEA preparation
JSEAs are followed once the job commences
Jobs are suspended and JSEAs modified when conditions change.
Shortfalls identified during routine monitoring should be corrected immediately at the
local level. If this is not possible, the next level of supervision should be engaged.
G1.3
Documentation
The Hazard/Risk Assessment should be documented using the Job Safety and
Environmental Analysis form (see Attachment 1-Offshore and/or (see Attachment 2Dynamic facilities) (see Attachment 3 - JSEAs for loading and unloading Trucks)
Job Safety and Environmental Analysis Steps
The basic steps in completing a Job Safety and Environmental Analysis are: (see
Attachment 4 for Job Safety and Environmental Analysis Flow Chart)
Step 1: Select the Job for Analysis
First, define the job to be analyzed. Large work packages should be divided into
smaller jobs or tasks, and these should be analyzed using the JSEA process.
Jobs suitable for JSEA can be performed in a day or less. JSEA shall be written in
detail to the way the job shall be performed. Examples include:
Operating a piece of machinery
Making an equipment repair
Installing Piping
Perform a jobsite Hazard Review utilizing the Pre-task Hazard Assessment
Inspection Checklist on back of JSEA.
Step 2: Break the Job down into Steps (Basic Job Steps)
The job should be broken down into a sequence of steps, or actions, required to
perform the job. The breakdown should not be so detailed that an unnecessarily
large number of steps result, or so general that basic steps are not recorded.
To determine the basic job steps, ask:
What action starts the job?, then
What must be done next?
And so on, until the entire job is described.
Note: Consider if simultaneous activities may affect the operation of this task?
The description of each step should begin with an action word, like Remove,
Open, Weld, Secure, etc.
Pre-job preparations (inspections, lock-out / tag-out, etc.) and post-job requirements
(clean-up, removal of locks and tags, etc.) should be included in the job steps.
G1.4
The job steps should be reviewed with experienced employees and those who will
do the work to be sure that the order is correct and no steps have been left out.
Step 3: Identify Hazards and Potential Accident Causes (Potential SH&E Concerns)
The purpose of this step is to identify all potential hazards associated with each step.
Hazards introduced by the work environment and the job tasks should both be
considered. Any hazards identified on the Pre-task Hazard Assessment Inspection
Checklist (back of JSEA) shall be identified within this portion of the JSEA.
The following questions can be used to help identify hazards:
Is there a danger of striking against, being struck by, or making other
undesired contact with an object or machinery?
Can an employee be caught in, by, or between objects or machinery?
Is there potential for a slip, trip or fall on the same level or to another?
Can employees strain themselves by pushing, pulling, lifting, bending, or
twisting?
Are all energy sources (electrical, mechanical, and process) controlled for
protection?
Are there hazards associated with simultaneous activities, which may affect
this task?
Other resources, such as Hazard Assessments, Work Permits or etc., can also be
used to identify hazards.
Record the hazards identified in the Potential SH&E Concerns column of the JSEA
form using the following format: Undesired result + hazard. For example, Struck
by hammer, Slip on wet floor, Shocked by electric motor, Burned by hot metal,
Fall from elevated work platform.
Step 4: Develop Solutions (Recommended Safe Procedure / Protection)
Next, those involved in the job must recommend safe job procedures, or protection,
to prevent the Potential SH&E Concerns identified in Step 3. Potential solutions
must be observable acts and may include:
Find a new way to do the job.
Change the physical condition that creates the hazard
Change the work procedure
Use proper safety equipment or safe practices
G1.5
G1.6
Attachment 1
G1.7
COATINGS DEPARTMENT
JOB SAFETY AND ENVIRONMENTAL ANALYSIS
Job #
Customer
Location
Date
Page
of
New JSEA:
Revised JSEA:
Y or N
Y or N
Job or Task
5.
Recommended Safe
Procedures/Protection
Responsible Party
Superintendent/Supervisor
Safety Equipment Required for this Task (Check all applicable). Inspect all PPE Prior to beginning Task.
Hard Hats:
Work Vest (PFD):
Fire Extinguishers/Firewatch:
Safety Shoes:
Face Shields:
LockOut / TagOut:
Safety Glasses:
Chemicals/Impact Goggles/Gloves:
Work Permit Required:
Leather, Cotton or Nitrile Gloves:
Hearing Protection:
Scaffolding:
Safety Harness & Anchor Device 100%:
Fall Protection Rescue System:
Gas Detection Meter:
This document certifies as a hazardous assessment for Personal Protective Equipment. Hot Work Activities require the review of the Gas Cutting/Welding Safety Guidelines prior to commencement
of work activities.
DII SAFETY 018 1F
G1.7.a.1
G1.7.a. 2
COATINGS DEPARTMENT
JOB SAFETY AND ENVIRONMENTAL ANALYSIS
G1.7.a. 2
G1.7.a. 2
CONSTRUCTION DEPARTMENT
JOB SAFETY AND ENVIRONMENTAL ANALYSIS
Job#
Customer
Location
Date
Page
of
New JSEA:
Revised JSEA:
Y or N
Y or N
Job or Task
Recommended Safe
Procedures/Protection
All employees involved in task inspect worksite using
the inspection form on back of JSEA Yes
No
- Review JSEA and Post at site
- Assign mentor with SSE N/A
- Identify communication process to be used
__________________________
- Bilingual employees will cover entire JSEA with
non English speaking employees
- Bilingual employees will work with non English
speaking employees
- Repair or replace defective tools / equipment / PPE
- Use only approved tools or lifting devices
- Identify method and location of Fall Protection
Rescue Method____________ Location___________
Receive Permit(s) from Operations
-No gloves
- Rings being worn
- Hands placed in between items that could move
- Hands placed on tools in non designated
location
5.
Responsible Party
Superintendent/Supervisor
Safety Equipment Required for this Task (Check all applicable). Inspect all PPE Prior to beginning Task.
Hard Hats:
Work Vest (PFD):
Fire Extinguishers/Firewatch:
Safety Shoes:
Face Shields:
LockOut / TagOut:
Safety Glasses:
Chemicals/Impact Goggles/Gloves:
Work Permit Required:
Leather, Cotton or Nitrile Gloves:
Hearing Protection:
Scaffolding:
Safety Harness & Anchor Device 100%:
Fall Protection Rescue System:
Gas Detection Meter:
This document certifies as a hazardous assessment for Personal Protective Equipment. Hot Work Activities require the review of the Gas Cutting/Welding Safety Guidelines prior to
commencement of work activities
DII SAFETY 016 1F
G1.7.a.5
G1.7.a.6
CONSTRUCTION DEPARTMENT
JOB SAFETY AND ENVIRONMENTAL ANALYSIS
G1.7.a.5
G1.7.a.6
Attachment 2
G1.8
Customer
Location
Date
Page
of 2
New JSEA:
Revised JSEA:
or N
or N
Job or Task Loading Equipment and/or material onto Trucks Trailer or Bed
Responsible Party
-STOP WORK, notify supervisor and resolve all reasons for STOP
WORK before restarting task
-Review and/or revise JSEA
Superintendent/Supervisor
G1.8.a.1
1. ________________________________
2._________________________________
3._________________________________
4._________________________________
5._________________________________
6._________________________________
7._________________________________
8._________________________________
9._________________________________
7
3.
4.
5.
6.
7.
8.
9.
G1.8.a.2
Drivers Signature:
Customer
Location
Date
Page
1 of 2
New JSEA:
Revised JSEA:
or N
or N
Job or Task: Off Loading Equipment and/or material from Trucks Trailer or Bed
Responsible Party
Recommended Safe
Procedures/Protection
Superintendent/Supervisor
G1.8.a.3
1._____________________________
2._____________________________
3._____________________________
4._____________________________
5._____________________________
6._____________________________
7._____________________________
8._____________________________
9._____________________________
7
12.
13.
14.
15.
16.
17.
18.
G1.8.a.4
Drivers Signature:
Customer
Location
Date
Page
of 2
New JSEA:
Revised JSEA:
or N
or N
Responsible
Party
Everyone involved in
task
3
4
-STOP WORK, notify supervisor and resolve all reasons for STOP
WORK before restarting task
-Review and/or revise JSEA
Everyone involved in
task
Mentors Name
______________
Superintendent/Superv
isor
Everyone involved in
task
G1.8.a.5
1. ________________________________
2._________________________________
3._________________________________
4._________________________________
5._________________________________
7
________________________________
_______________________________________
________________________________
_______________________________________
________________________________
_______________________________________
________________________________
_______________________________________
Equipment Operator(s)
and Riggers
Equipment Operator(s)
and Riggers
20.
21.
22.
23.
24.
25.
27.
Designated Signal
Person is:
1._____________
__________________________________________
19.
G1.8.a.6
26.
Drivers Signature:
SEGURAS RAPID PRESS 337-365-0749
Attachment 3
G1.9
Sr. Mgmt.
Supervisor
Task
Leader
Periodically Audit the JSEA Process and Communicate Audit Findings (As part of SH&E MS)
Select
Job for
Analysis
(Step 1)
Perform
Jobsite
Hazard
Review
Prepare Draft
JSEA *
(Steps 2-4)
Review JSEA
w/ Crew
(Step 5)
Modify JSEA
to address
changes
Sign JSEA
Form to
indicate
Agreement
(Step 5)
Y
Review JSEA /
Give Feedback
(Step 5)
Crew
Customer
Notes:
*
**
Changes?
(Step 5)
Post JSEA
at Job Site
and
Conduct Job
as described
in JSEA
Keep JSEAs on
file for future
reference and
audits
Y
Job
Changes?
**
(Step 6)
Participate
As
Appropriate
Monitor
Job
G1.9.a.1
Page 1 of 7
Original: 01/01/2001
Revised: 01/01/2010
Upon receiving incident documents the Manager shall review and forward to
the SH&E Department.
Medical Attention Required:
Should the injured employee require medical attention, the supervisor shall
notify his immediate Manager.
Prior to notifying the SH&E Department the Manager shall arrange
transportation to closest company designated medical facility. If the SH&E
Department is unable to arrive at the medical facility prior to the injured
partys arrival, the Manager shall Fax the Approval for Medical Attention
(see Attachment 3) to the medical facility.
The supervisor shall complete the First Report of Injury or Occupational
Illness / Property Damage Report (see Attachment 2).and the Moreno Group
LLC and Subsidiaries Work Group Investigation (see Incident Investigation
Procedure). The supervisor shall obtain a copy of any Third Party Accident
Report and attach these reports to the incident documents.
The supervisor shall forward to their immediate Manager the completed
incident reports within 24 hours.
Upon receiving the incident documents, the Manager shall review, approve
and forward documents to the SH&E Department.
First Aid
All Moreno Group LLC and Subsidiaries facilities will have readily available approved
first aid kit located in the Safety, Health and Environmental Department. All Offshore
tool houses will be provided with a USCG Approved First Aid Kit and Bloodborne
Pathogens Kit.
Inspection of First Aid Kits
Weekly the Facility Management and the Safety, Health and Environmental
Department shall be responsible for checking and maintaining the First Aid Kits
located at each facility. The tool room shall be responsible for providing fully stocked
USCG first aid kits which is a weather proof container with sealed packages of each
type of item in all offshore tool houses prior to sending the offshore tool house
offshore.
Training
First Line Supervisors, Offshore Superintendents and the Safety, Health and
Environmental Department shall be trained in American Heart CPR, First Aid and
Bloodborne Pathogens. Retraining will be annual for American Heart CPR and
Bloodborne Pathogens and every two years for First Aid. These records will be
maintained by the Safety, Health and Environmental Department.
Attachment 1
Moreno Group LLC and Subsidiaries Incident Reporting Procedure Flow Chart
Incident
Supervisor Notifies Division
Manager to arrange
transportation to medical facility
Employee Notifies
Supervisor
Supervisor confirms
employees need for
medical attention
Supervisor notifies
Client of Incident
Division Manager notifies SH&E
Department
Division Manager
reviews with and
provides forms to
SH&E Department
YES
Medical
Attention
Needed
NO
SH&E representative
arrives at medical
facility prior to injured
employee
Supervisor completes Incident
Report & Incident Investigation
forms and faxes to Division
Manager
Supervisor completes
Incident Report &
Incident Investigation
forms and faxes to
Division Manager
NO
YES
SH&E representative
performs Post Injury
Management
SH&E Department
notifies Division
Manager and Upper
Management of
employee condition
Attachment 2
Type of
Injured Party
Incident
Injury
Occupational Illness
Property Damage
Information Only
Fire
(Non-Occupational)
Crane Incident
Vessel Collision
Moreno employee
Subcontractor
When
Facility
Information
State: _________________________________
Vessel
Informa- Body Part
tion
Shoulder (L/R)
Hand (L/R)
Hip (L/R)
Arm (L/R)
Finger or Toe
Leg (L/R)
Torso
Knee (L/R)
Elbow (L/R)
Internal
Ankle (L/R)
Wrist (L/R)
Back
Foot (L/R)
Description
of Incident
Property
Damage
Witnesses
Attachment 3
Date
Medical Facility
Address
Doctors Statement
Name of injured employee
Date of Treatment
Will the employees physical condition allow him or her to return to
work
Should physical condition permit
employee to return to work, is the work
Regular Duty
Yes
No
Restricted Duty
Incident Investigation
Procedure
Page: 1 of 11
Original: 02/09/1998
Revised: 12/01/2009
completion
of
approved
H2.1
Retention of incident reports and supporting documentation for five (5) years.
Conducting a 30-day follow-up on all outstanding recommendations and
providing management with a monthly exception list of all overdue action
items.
Overseeing this policy and insuring all requirements are met.
Auditing compliance with this policy.
Understanding and complying with this policy / procedure.
Timely notification of management and Safety Department concerning
incidents occurring in their areas of responsibilities
Preservation of the incident scene until released to the investigation team.
Investigating or participating in the investigation of all job related accidents,
injuries, illnesses or near-miss events that occur in their area(s).
Completing the Workgroup Incident Investigation (Attachment 1).
Assuring adequate short-term interim measures are taken to allow safe
resumption of work.
Completing any assigned report recommendations.
Communication of report findings and corrective actions to subordinates.
Documentation of investigation findings and corrective actions and submitting
to the Facility / SH&E Department / designee for filing.
Issuing the Workgroup Incident Investigation Form to the Facility / Site
Manager within 24 hours.
The Safety, Health and Environmental Department is responsible for:
Reviewing all completed Workgroup Incident Investigation Forms and
Witness Statements.
Participating in the actual investigation of accidents or incidents with the
potential for serious personal injury, property damage or damage to the
environment.
Assignment of a unique report number that will be entered on all reports,
attachments and / or evidence.
H2.2
employee is not able to attend the investigation, the work group shall
meet the day of the incident to gather information and conclude the
investigation when the affected employee is available. In some cases,
more than one work group may be included in the Work Group
Investigation.
Use the Work Group Investigation Form to document team findings
and recommendations (see Procedure Section for guidelines for
conducting a Work Group Investigation). The completed investigation
form is forwarded to the Yard Foreman/Offshore Manager who shall
review the work group investigation. The Yard Foreman/Offshore
Manager will arrange for a supplemental investigation (if required) or
forward the form to their Facility Manager for review and approval then
the Safety, Health and Environmental Department for tracking and
follow-up.
Supplemental Investigation All incidents involving an OSHA Days
Away From Work incidents shall receive a supplemental investigation.
The Yard/Offshore Manager who reviewed the Work Group
Investigation has the responsibility to arrange for the Supplemental
Investigation. Use the Supplemental Investigation Form to document
team findings and recommendations.
The purpose of the
supplemental investigation is to involve the appropriate level of
managers and employee representatives in the more-serious incident
reviews to aid with identifying underlying causes, corrective actions,
and assign action-item responsibilities. Use the Work Group
Investigation Report as preliminary information for the supplemental
investigation. A copy of the completed Work Group Investigation form
shall be attached to the Supplemental Investigation Form.
Conducting a Work Group Investigation
The following guidelines are provided to promote consistent incident
investigation methods using the Work Group Investigation Form. Elements of
each section of the Work Group Investigation Form are included along with
suggested items for discussion.
Information Block Print the employees name, date and time of the
incident, job classification, area or work unit where the incident
occurred, specific incident location, the date and time the incident was
reported, and the employees supervisor.
Investigation Team Members Print the names of all team members
present during the Work Group Investigation. This is not a signature
block.
Incident Information
Incident Description Print or write legibly a complete
description of the incident, i.e. What happened, who was
H2.5
Management Systems
Administrative Controls Was inadequate staffing or time
allotment a factor? Were priorities unclear or conflicting?
Engineering Controls Were standards, specifications,
and/or design adequate? Were Management of Change
procedures followed?
Preventative Maintenance/Inspection Was the work
scheduled properly? Were the proper parts used? Was an
improper extension of service life/inspection period made?
Other List applicable management systems not included
above.
Additional Preventive Actions/Recommendations List
preventive actions or recommendations, which were not
included in the Work Group Investigation.
Incident Investigation Training
The SH&E Department will provide Incident Investigation Training to all
Management, First Line Supervision / Offshore Superintendents and/or any
designated individuals responsible for incident investigations. This training should
include incident investigation techniques, tools to be use (i.e. cameras, drawings,
etc.) during the investigation and Dynamic Industries, Inc. Incident Investigation
process / procedure to help ensure contributing factors and root causes that are
associated with the incident are appropriately identified and preventive actions /
recommendations are recommended and implemented to completion to prevent any
reoccurrence.
H2.8
Attachment 1
H2.9
Employees Supervisor
Date/Time Reported
Investigation Date:
4.
7.
5.
8.
6.
9.
Witness(es):
Immediate corrective actions:
CONTRIBUTING FACTORS Did any of the following factors contribute to the Incident (Check Yes/No If
yes, explain)
Training: Yes
No
No
No
Other: Yes
No
No
No
No
ROOT CAUSES
Target Completion
Date
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
SIGN-OFF
Offshore Supt/Supervisor
Date:
Date:
Date:
Vice President
Date:
Attachment 2
H2.10
Investigation Date:
4.
8.
1.
5.
9.
2.
6.
10.
3.
7.
11.
H2.10.a.1
ROOT CAUSES
1.
2.
3.
4.
5.
SIGN-OFF
INVESTIGATION TEAM MEMBERS:
1.
Date:
2.
Date:
3.
Date:
4.
Date:
5.
Date:
6.
Date:
7.
Date:
8.
Date:
9.
Date:
10.
Date:
H2.10.a.2
Target Completion
Date
Attachment 3
H2.11
Company:
Employee Supervisor:
Employee SSN:
Incident Date:
Incident Time:
Incident Location:
To the employee involved or the employee who witness the incident- Briefly explain in your own
words the circumstances that led to the incident occurring. Also include your involvement in the
incident. Your comments are important to help determine the causes of the accident and correct any
unsafe conditions. Thank you.
I have written the above statement and certify that it is true to the best of my knowledge.
Employee / Witness Signature:
Date of Signature:
Supervisors Signature:
Date of Signature:
H2.11.a.1
Occupational Health
Program
Page 1 of 5
Original: 01/01/2001
Revised: 05/01/2008
- NORM
- Lead
- H2S
- Heat/Cold exposure
- Silica
I1.2
In addition to specific exposure programs, Moreno Group LLC and Subsidiaries will
implement the following general programs:
- Hazard Communication
- Hearing Conservation
- Bloodborne Pathogens
- NORM
- Respiratory Protection
- Lead
- Asbestos
- H2S
- Benzene
An industrial hygiene hazard assessment will be conducted once every five years for
all facilities and shall be consistent with the hazard analysis requirements of the
companies Safety, Health and Environmental Policies. The results of these
assessments will be included into the facility hazard assessments in accordance
with the Moreno Group LLC and Subsidiaries Safety, Health and Environmental
Management System.
Exposure Control Measures
The measures to be utilized to control worker exposure will be determined by the
nature of the chemical or physical agents and the level of exposure identified by the
hazard assessment. The following outlines the various methods of control measures
(but not limited to) available to Moreno Group LLC and Subsidiaries to eliminate or
reduce the worker exposure time or the reduction of contaminant the worker is
exposed to.
Process or Material Changes
The substitution of a hazardous material for one that is less harmful to
health
Change or alteration of a process or operating procedure
Engineering Controls
Isolation or enclosure to reduce the number of employees exposed
Isolation or enclosure of a worker in a control booth or area
Wet methods to reduce the generation of dust
Local exhaust ventilation at the point of generation or dispersion of
contaminants
General or dilution ventilation
Shielding devices
I1.3
PPE Controls
Personal protective equipment
Good housekeeping and maintenance
Administrative Controls
Adjusting work schedules, rotating job assignments, etc.
Medical surveillance to detect evidence of exposures
Personnel Training
Training and education to supplement all the above
A combination of the methods may be necessary to effectively control the workers
exposure to the chemical or physical agents.
Management is responsible for
providing the needed training, facilities, equipment and products to provide the
worker with a safe and healthful work place.
Monitoring Plan
Moreno Group LLC and Subsidiaries will utilize one or more of the following methods
to assist them in the hazard assessment. The Moreno Group LLC and Subsidiaries
Occupational Health Programs and Management of Change process will determine
the frequency and timing of required monitoring.
Personal Personal monitoring is the measurement of worker specific exposure to a
potentially hazardous substance identified by each specific program and the
programs exposure profile for each target job. The monitor will be placed as close
as possible to the site at which the contaminant enters the body. For instance, when
sampling for noise the device will be place as close to the ear as possible. When
sampling for respirable contaminates the monitoring or capture device will be placed
as close to the workers breathing area as possible without affecting his comfort.
Environmental Environmental monitoring is used to monitor the concentrations of a
contaminant in a general area of the workplace as close to the worker as possible.
Biological Biological monitoring measures the changes in composition of body
fluid, tissues or expired air to detect the level of contaminant absorption. For
instance, Personnel placed in a lead exposure abatement program will have blood
analyzed for lead content.
I1.4
I1.5
Abrasive Blasting
Page: 1 of 12
Original: 01/01/2004
Revised: 04/15/2009
Abrasive Blasting
Purpose
The purpose of this procedure is to establish a formal process for blasting operations
and to give a basic outline of expectations and procedures.
Scope
This is intended to be a minimum standard for Moreno Group LLC and Subsidiaries
facilities for the safe work practices and procedures while performing abrasive
blasting.
The Facility / Site Manager / Offshore Manager or Designee is responsible for:
Provide the needed leadership, commitment, employee empowerment, and hold
personnel accountable for the implementation of this procedure.
Communicating to work force their commitment to the stopping of work, if any
unsafe condition or situation is present.
Auditing compliance with this procedure.
Being knowledgeable of the applicable safety and health regulations associated
with this program.
The First Line Supervisor / Offshore Superintendent is responsible for:
Understanding and complying with this procedure.
Ensuring that all employees are working safely while blasting operations are
being conducted and perform a pre-job check of all equipment and PPE before
work commences.
Conduct pre-job safety meetings and JSEAs with all affected personnel to
identify scope of work, associated job hazards involved, proper precautions for
work planned and PPE.
If scope of work changes, Stop All Work and relate information to all affected
personnel by means of safety meeting and JSEA.
Continually communicate employees responsibility to use their Stop Work
Authority.
I2.1
I2.2
Requirements
The Abrasive Blasting program is to implement Safe Work Practices and controls
when working with abrasive blasting material and equipment. Exposure can be the
result of operations that are being performed with abrasive blasting and can include
the following:
1. Respiratory implications from improper use of personal protective equipment.
2. Exposure to affected employees in adjacent areas to those where abrasive
blasting tasks are being performed.
3. Hearing conservation when working with abrasive blasting equipment or
around areas where abrasive blasting operations are being conducted.
4. Risk of injury from malfunctioning of blasting equipment or from improper
maintenance of such, or as the result of blasting operations.
5. Exposure to substances such as lead on painted material that is blasted.
The Painting and Blasting Foreman is responsible for the implementation and
enforcement of this procedure, as well as other procedures that pertain to the scope
of work being performed.
The SH&E Department shall assist in routine auditing of the procedure and
implementation of the procedure to ensure that the procedure is being complied
with.
Employees performing work must comply with the provisions of this procedure as
per training and instructions received, and wear all protective equipment required.
Hazards
A respiratory hazard, called silicosis, is the prevalent hazard. There are 3 types of
silicosis:
1. Chronic/classic: The most common, usually occurring after 10 years of
exposure to low concentrations. Symptoms may or may not be obvious.
Some symptoms in late stages of silicosis may include fatigue, shortness of
breath, chest pain or respiratory failure.
2. Accelerated silicosis: Can occur after only 5-10 years of high exposure to
respirable crystalline silica.
3. Acute silicosis: Occurs after a few weeks to a few years following exposure to
extremely high concentrations of crystalline silica.
Exposure occurs during many different construction activities. The most severe
exposures have occurred during abrasive blasting with sand to remove paint and
rust from surfaces. Silica dust causes severe fungal infections to develop; this
condition could be fatal.
I2.3
Methods of Compliance
Methods of compliance that reduce or eliminate the risk of exposure include
Engineering Controls, Administrative Controls, Safe Work Practices and Training.
Engineering Controls
Engineering Controls, methods of isolating or removing a hazard from the
workplace, are one of the most effective methods of hazard reduction. Engineering
controls will be utilized to eliminate and / or reduce the exposures of respiratory
hazards associated with abrasive blasting below the PEL. Examples of the
engineering controls to be utilized is:
Ventilation
Containing of area utilizing screens or heavy canvas
The use of alternative blast media
Recovery Systems
Blasting Rooms or cabinets
Deadman controls on airlines.
Personal and area air sampling will be performed per Moreno Group LLC and
Subsidiaries Occupational Health section of this manual. Air monitoring results
should confirm that the engineering controls, administrative controls, Safe Work
Practices and Personal Protective Equipment being utilized are protecting the
employee from hazards related to abrasive blasting. Should air monitoring results
indicate the hazards are not controlled under the NIOSH PEL, the abrasive blasting
process will be stopped until appropriate controls are reevaluated and implemented.
The following minimum Personal Protective Equipment shall be worn at all times
during the abrasive blasting process:
Respiratory Protection (Supplied-Air Respirator helmet or bullet hood with
inner shield)
Hearing Protection
Gloves (leather)
Steel toed shoes
When needed, Tyvek Suit to be worn over work clothes
I2.4
The main type of respiratory protection for personnel using blast equipment will be a
Supplied-Air Respirator (SAR) otherwise known as a helmet or bullet hood. This
protects the user by protecting his head, respiration, neck, and shoulders. The
regulator is carried on the waist normally, using a belt clip. The hood constantly
blows breathing air on the user, which keeps the hood at a slight positive pressure
above ambient atmospheric pressure. This pressure will prevent contaminants from
entering the hood, since air is escaping out.
The air used for Supplied Air Respirators shall be of Grade D breathing air, which is
air of high purity. Grade D breathing air must meet the following standards:
Oxygen 19.5%-23.5%
Hydrocarbons - 5 mg per cubic meter or less
Carbon Monoxide - 10ppm or less
Carbon Dioxide - 1000ppm or less
Lack of noticeable odor
Suitable in-line air purifying sorbent beds and filters shall be used to ensure
breathing air quality. Sorbent beds and filters shall be maintained and replaced or
refurbished periodically following the manufactures recommendations.
If oil lubricated compressor is providing air to the airline respirator, the following
conditions shall be confirmed:
High temperature or carbon monoxide alarm or both, to monitor carbon
monoxide levels. If only high temperature alarms are used, the air supply
shall be monitored at intervals (i.e. at least daily) sufficient to prevent carbon
monoxide in the breathing air from exceeding 10 ppm.
Air lines and fittings that supply respirable air shall not be interchangeable to other
services.
All respirators shall be cleaned in warm water with a mild detergent or with a cleaner
recommended by the manufacturer and properly stored after each use.
Administrative Controls
Administrative controls will be utilized when the Facility Manager or designee
determines or is advised that engineering controls are not providing adequate
protection. Administrative controls can consist of the following:
Scheduling of the abrasive blasting process
Rotating Job Assignments
Medical Surveillance
I2.5
Medical Surveillance
All employees who run the risk of coming in contact with airborne silica dust will go
through the following procedures:
Pre-employment physical with a physician. This will include a medical &
occupational history to collect data on a workers past exposure.
Pulmonary function test (PFT) and evaluation by medical personnel for preemployment and annually there after.
Respirator Protection Questionnaires to be filled out be employees and
evaluated by medical personnel.
Chest X-rays for pre-employment physical and every three (3) years there
after.
Quantitative or Qualitative fit test to assess the adequacy of respirator fit preemployment and annually there after. Note: all personnel taking either fit
test must be clean-shaven!
More frequent examinations may be necessary for workers at risk or acute or
accelerated silicosis. Exams should include at least the following:
Medical and Occupation history to collect data on worker exposure
Chest X-ray
Pulmonary Function Testing
Annual Evaluation for Tuberculosis
The utilization of personal air monitoring and medical evaluations by the Company
Physician will determine if more frequent examinations should be conducted.
Anytime an employee is diagnosed with silicosis, the State Health Department and
OSHA will be notified. All cases of silicosis are recordable under the OSHA
Recordkeeping guidelines.
Safe Work Practices
Methods that reduce the exposure during a task or procedure will be used to
minimize exposure. All employees who have the potential of coming in contact with
blasting operations shall follow the following Safe Work Practices:
Know which work operations can lead to silica exposure. Signage will be
utilized to identify these areas within the facility.
I2.6
(see
Areas adjacent to blasting operations shall be properly protected with the use
of sand screens to prevent emissions to areas other than blasting areas.
Tarps or screens should be installed whenever airborne emissions become
an irritant to adjacent work areas where employees are working, or where
there is a safety issue, as in blasting on lead painted surfaces. Tarps or
screens that are installed on lead painted structures that will be blasted will be
approved by the SH&E Department prior to any blasting activities beginning.
Employees shall follow the procedure for hooking up blast hoses. (See
Attachment 2)
Housekeeping
Good housekeeping involves a regular schedule of housekeeping activities to
remove accumulations of dust and debris. The schedule should be adapted to
exposure conditions at a particular worksite.
Supervision
Good supervision is another important work practice. It provides needed
support for ensuring that workers follow proper work practices. By directing a
worker to position the exhaust hood properly or to improve work practice, a
supervisor can do much to minimize unnecessary employee exposure to
airborne contaminants.
Various types of blasting media may be used, depending on client
specifications. Precautions should be made with each media type and safe
work practices implemented as such.
Material safety data sheets are to be referenced for each blasting media to be
utilized and all appropriate precautions should be taken as indicated in data
sheets regarding safety, health and environmental concerns.
I2.7
Blasting nozzles are equipped with dead-man controls to allow the operator to
start and stop blasting with one hand.
Dead-man controls shall never be taped or wired open. This would not allow
the operator to shut down blasting rapidly, should the need occur.
Pressure pots (i.e. sand pots) shall meet the most current ASME Boiler and
Pressure Vessel Code requirements
Pressure pots shall have all associated equipment (i.e. locking valves,
gauges, etc) identified within attachment 2.
Energy Isolation Procedures (i.e. Lockout / Tagout) shall be followed prior and
during the loading of all pressure pots (i.e. sand pots). Only the Offshore
Superintendent or designated Foreman shall open sand pots.
Machines, hoses and equipment (i.e. deadman controls, sand pots, etc.) must
be inspected daily with deficiencies logged down. Defective equipment must
be replaced immediately before work is resumed.
All hoses shall have safety pins and whipchecks on the connectors to prevent
inadvertent disconnection.
Never adjust nozzle with the abrasive flowing.
Respirators shall be inspected before each use and during cleaning, and shall
be cleaned after each use. Respirator inspection shall include the following:
o Check for function, tightness of connections, and the condition of the
different parts including, but not limited to, the face piece, head straps,
valves, connection tube, cartridges, and filters.
o Check plastic and rubber parts for pliability and signs of deterioration.
o All inspections shall be done per manufacturers specifications.
o If using respirators, do not alter the respirator in any way.
All areas that are adjacent to blasting operations shall be properly guarded
against sand emissions by the use of blasting screens or tarpaulin. No
blasting shall be conducted until all areas are appropriately guarded and all
areas are protected.
All vehicles should be parked in designated areas and not within
contaminated areas.
The SH&E Department shall make final approval prior to blasting on surfaces
that contain lead based paint.
I2.8
Training
All employees subject to potential silica exposures shall be provided information
about adverse health effects, work practices, Hazard Communication, Safe Work
Practices and use and care of personal protective equipment. The following training
topics will perform as part of Moreno Group LLC and Subsidiaries New Employee
Orientation / SH&E Training and as needed there after:
Signs and Symptoms of silicosis
Hazards associated with abrasive blasting.
Methods and equipment used for personnel protection including respiratory
protection.
Safe Work Practices to be utilized for abrasive blasting operations.
Personal hygiene practices associated with blasting operations.
Inspection, care, proper use and storage of personal protective equipment
and respiratory equipment.
I2.9
Attachment 1
I2.10
I2.10.a.1
Attachment 2
I2.11
Deadman
Picture 1
4) When connecting the twin lines to the control valves on the sand pot a qualified employee will connect
the Supply Airline of the twin lines to the Supply Air Fitting on the control valve of the sand pot.
(Refer to picture 2)
to deadman
Picture 2
5) The Return Airline coming from the deadman to the control valve on the sand pot will not be
hooked up to the control valve on the sand pot at this time.
6) The qualified employee will open the valve to supply air to the control valves. He will hold the return
airline and have the blaster activate the deadman. If air comes out of the return line then he will
have the blaster release the deadman. This verifies that this twin line is connected to the correct
deadman. (refer to picture 3)
I2.11.a.1
Picture 3
7) The qualified employee will connect the return airline to the pilot valve. (refer to picture 4)
Picture 4
8) The qualified employee will then label the control valve. Labeling can be color tape, duct tape labeled with a
number or duct tape with the blasters name. The blaster will label the deadman the same as the control valve
on the sand pot. (Refer to picture 5 &6)
Picture 5
I2.11.a.2
Picture 6
Attachment 3
I2.12
Aluminum
Cam Lock Lid
Lock Out
Device
Pressure Relief
Valve, Secondary
Pressure Gauge,
Secondary Bleed
Off Valve
Primary
Pressure
Gauge
Auto Air
Valve Pilot
Valve 1
Choke Valve
1 Ball Valves
Thompsons
Valves
I2.12.a.1
Aluminum Protection
Page: 1 of 10
Original: 01/12/2005
Revised: 05/01/2008
Aluminum Protection
Purpose
The purpose of this program is to establish and implement practices and procedures
for protecting the health of Moreno Group LLC and Subsidiaries employees who
may be exposed to aluminum on the job. This program also establishes methods for
complying with the OSHA Construction Industry Air Contaminants, 29 CFR
1910.1000.
Scope
The scope of this program applies to all Moreno Group LLC and Subsidiaries
projects and employees involved with aluminum construction projects and activities.
This program also applies to all subcontractors, working under the direct control of
Moreno Group LLC and Subsidiaries, involved with aluminum construction projects
and activities. Subcontractors must provide all manpower, supplies, equipment,
training, and medical examination and testing necessary to comply with this
program.
Responsibilities
The Facility Manager / Yard Foreman or designee is responsible for:
Informing the SH&E Department of the any upcoming project that may have
the potential of containing aluminum exposure.
Inform any subcontractors that may be working on the project that aluminum
exposure may be possible.
Ensure that subcontractors understand and comply with this policy.
The First Line Supervisor is responsible for
Understanding and complying with this policy / procedure.
Designating employees for the project and ensuring that a list of employees is
provided to the SH&E Department to report to the Medical Review Officer to
be placed in a medical surveillance program and receive all necessary
surveillance prior to job commencing, such as Pulmonary Function Testing
and questionnaire, as well as chest X-rays.
I3.1
I3.2
I3.3
I3.4
I3.5
exposure,
concentrations and
I3.6
WARNING SIGNS
Warning signs will be posted in the work area around activities where
airborne aluminum exposures may exceed the PEL. The work area can be
demarcated by Yellow Caution tape.
Signs will be posted at every accessible side of the work area. These signs
will be easily visible from a distance so that employee can read the sign and
take necessary protective measures before entering the work area. Signs will
read as follows: WARNING, ALUMINUM WORK AREA.
The competent person will control access of persons into work area.
All persons entering work areas will wear protective clothing and respirators.
Eating, drinking, smoking, and chewing is prohibited in work areas and any
area where airborne aluminum exposure may exceed the PEL.
CONTAINMENTS
Where required by federal, state, or local regulation, the project sponsor, or
the project owner, containments will be constructed and used as specified.
The purpose of containments is to restrict or prevent the spread of airborne
aluminum or debris to surrounding areas or the environment. While the
proper use of containments can help protect the public and the environment,
they generally cause a significant increase in airborne aluminum
concentrations in the work area. Containments may increase the potential for
higher employee aluminum exposures. Therefore, the use of well designed
exhaust ventilation and the use of more protective respirators may be
necessary to properly protect workers.
Containments may include any of the following:
Rigid or flexible barriers or sheets surrounding the work area
Complete unventilated enclosures built around the work area
Complete enclosures maintained under negative pressure by exhaust
ventilation with exhaust air filtration
Containments may also require the construction and use of platforms or
scaffolding. These may be stationary or movable, ground supported or
suspended.
I3.7
I3.8
I3.9
I3.10
Asbestos
Page: 1 of 18
Original: 01/01/2008
Revised: 06/01/2009
Asbestos Program
Purpose
The purpose of this program is to provide for Moreno Group LLC and Subsidiaries
employees and contractors an acceptable method for managing an environment that
shows potential for employee exposure to asbestos that is at or above the Permitted
Exposure Level. (PEL)
Scope
The scope of this document will be to describe methods of eliminating or
minimizing exposures to Asbestos by the following methods:
Asbestos Identification,
Engineering Controls and Procedures,
Personal Protective Equipment (PPE),
Employee Training Requirements,
Employee Medical Requirements,
Administrative Control.
Moreno Group LLC and Subsidiaries will make every reasonable effort to ensure
that no employee is exposed to an airborne concentration of asbestos in excess of
the current PEL, but provides contingency for exposure that includes, at a minimum,
medical surveillance.
This program applies to all work where one of our employees may be occupationally
exposed to asbestos. All work related to abatement, construction, alteration, or
repair, including painting and decorating, during the removal of Asbestos Containing
Material (ACM) within dry walls, insulation, floor tile, etc. The Moreno Group LLC
and Subsidiaries, Facility Manager is responsible for its implementation, and copies
of this written program may be obtained from this person.
I4.1
Responsibilities
The Facility Manager / Site Manager or Designee is responsible for:
Understand and comply with the requirements of this procedure. Ensure that
personnel with potential for exposure to asbestos are placed into any
mandated medical surveillance program
Ensure that all work activities and documentation of this program are
maintained on site, during the course of activities that have potential to
precipitate employee possible exposure to asbestos.
Ensure that personnel performing asbestos monitoring are qualified to do so,
and are adequately trained to the degree that monitoring results can be
considered reasonably accurate.
Audit compliance with the procedure.
The First Line Supervisor or Designee is responsible for:
Understand and comply with the procedure.
Confer with Facility/Site Mgr., SH&E Dept., or Designee as to any potential or
suspected asbestos exposure.
Ensure that personnel assigned to tasks that involve potential asbestos
exposure are placed into any mandated medical surveillance program that is
appropriate for asbestos
Ensure that employees performing tasks with potential for asbestos exposure
are adhering to all rules set out in the Job Safety and Environmental Analysis
(JSEA), including use of all appropriate PPE.
Make suggestions to Management and/or other appropriate individuals
concerning improved asbestos management techniques or procedures.
Initiate resolution of any situation in which an employee has exercised his/her
Stop Work Authority.
The SH&E Department or designee is responsible for:
Understand and comply with procedure.
Coordinate and conduct (or cause to be conducted) all asbestos related
training, (to include, but not limited to) all elements of appropriate Respiratory
Protection Program.
I.4.2
I4.3
Director means the Director of the National Institute for Occupational Safety
and Health, U.S. Department of Health and Human Services, or designee.
Employee exposure means that exposure to airborne asbestos that would
occur if the employee were not using respiratory protective equipment.
Exposure to asbestos has shown but may lead to but not limited to lung
cancer, asbestosis, mesothelioma, and cancer of the stomach and colon.
Fiber means a particulate form of asbestos 5 micrometers or longer, with a
length-to-diameter ratio of at least 3 to 1.
Friable means material that can be crumbled with hand pressure and is
therefore likely to emit fibers.
High-efficiency particulate air (HEPA) filter means a filter capable of
trapping and retaining at least 99.97 percent of 0.3 micrometer diameter
mono-disperse particles.
Homogeneous area means an area of surfacing material or thermal system
insulation that is uniform in color and texture.
Industrial hygienist means a professional qualified by education, training,
and experience to anticipate, recognize, evaluate and develop controls for
occupational health hazards.
Non-Friable means a material that generally does not emit airborne fibers
unless subjected to sanding or sawing operations.
PACM means presumed asbestos containing material.
Presumed asbestos containing material means thermal system insulation
and surfacing material found in buildings constructed no later than 1980. The
designation of a material as "PACM" may be rebutted pursuant to paragraph
(j)(8) of this section.
Regulated area means an area established by the employer to demarcate
areas where airborne concentrations of asbestos exceed, or there is a
reasonable possibility they may exceed, the permissible exposure limits.
Surfacing ACM means surfacing material which contains more than 1
percent asbestos.
Surfacing material means material that is sprayed, troweled-on or otherwise
applied to surfaces (such as acoustical plaster on ceilings and fireproofing
materials on structural members, or other materials on surfaces
for acoustical, fireproofing, and other purposes).
I4.5
I.4.6
Medical Surveillance
A medical surveillance program will be instituted for all employees who for a
combined total of 30 or more days per year are engaged in Class I, II, and III work or
are exposed at or above the PEL.
When our employees are required by the standard to wear a negative pressure
respirator, we make sure those employees are physically able to perform the work
and use the equipment as determined by a physician. Documentation of pulmonary
function tests, fit tests, and respirator training is available through the SH&E
Department.
We ensure that all medical examinations and procedures are performed by or under
the supervision of a licensed physician, and are provided at no cost to the employee
and at a reasonable time and place.
Our medical surveillance program includes the following:
1. Medical examinations and consultations
Medical examinations and consultations are available to each employee as
required by the OSHA Standard. .
When our employee is assigned to an area where exposure to asbestos may
be at or above the PEL for 30 or more days per year, or engage in Class I, II,
or III work for a combined total of 30 or more days per year, a medical
examination must be given within 10 working days following the thirtieth day
of exposure; and at least annually thereafter.
2. Information provided to the physician
The following information will be provided to the examining physician:
A copy of the asbestos standard including Appendices D, E, and I. (as
requested)
A description of affected employees' duties as they relate to their exposure.
The employees' representative exposure level or anticipated exposure level.
A description of any personal protective and respiratory equipment used or to
be used.
Information from previous medical examinations that is not otherwise
available to the examining physician.
3. Physician's written opinion
The written opinion of the examining physician should minimally contain the
results of the medical examination and diagnostic procedures.
I4.7
Recordkeeping
Data
Where we rely on IH Monitoring and Product Sampling that demonstrates that
products made from or containing asbestos or the activity involving such products or
material are not capable of releasing fibers of asbestos in concentrations at or above
the permissible exposure limit and/or excursion limit under the expected conditions
of processing, use, or handling, the product data will minimally include:
The testing protocol, results of testing, and/or analysis of the material for the
release of asbestos.
A description of the operation exempted and how the data support the
exemption.
Other data relevant to the operations, materials, processing, or employee
exposures covered by the exemption.
We maintain this record for the duration of the employer's reliance upon such data.
Exposure Measurements
An accurate record of all measurements taken to monitor employee exposure to
asbestos as prescribed by the OSHA Standard will be maintained.
Note: We may utilize the services of competent organizations such as industry trade
associations and employee associations to maintain the records required by this
section.
This record includes at least the following information:
The date of measurement.
The operation involving exposure to asbestos that is being monitored.
Sampling and analytical methods used and evidence of their accuracy.
Number, duration, and results of samples taken.
Type of protective devices worn, if any.
Name, social security number, and exposure of the employees whose
exposures are represented.
We will maintain this record for at least thirty (30) years.
I.4.8
Medical Surveillance
We have established and do maintain an accurate record for each employee subject
to medical surveillance.
The record includes at least the following information:
The name and social security number of the employee.
A copy of the employee's medical examination results, including the medical
history, questionnaire responses, results of any tests, and physician's
recommendations.
Physician's written opinions.
Any employee medical complaints related to exposure to asbestos.
We make sure that this record is maintained for the duration of employment plus
thirty (30) years.
Training and Training Records
Training will be provided to all employees who maybe potential exposed to Asbestos
Containing Material prior to their initial assignment and annually thereafter if
required. All employee training records will be kept for one (1) year beyond the last
date of employment.
Data to Rebut PACM
Where the building owner and we have relied on data to demonstrate that PACM is
not asbestos-containing, we maintain such data for as long as they are relied upon
to rebut the presumption.
Competent Person Requirements
At the worksite covered by this plan, we have designated Moreno Group LLC and
Subsidiaries Construction Manager, and Moreno Group LLC and Subsidiaries
Environmental Manager, or their qualified agent as our competent person, having
the qualifications and authorities for ensuring worker safety and health.
Inspections
In addition to our initial inspection, the designated competent person will visit the job
sites to supervise the following:
For Class I jobs, on-site inspections are made at least once during each work shift,
and at any time an employee requests one.
I4.9
For Class II, III, and IV jobs, on-site inspections are made at intervals sufficient to
assess whether conditions have changed, and at any reasonable time an employee
requests.
On all worksites where our employees are engaged in Class I or II asbestos work,
our competent person will perform or supervise the following duties, as applicable:
Set up the regulated area, enclosure, or other containment.
Ensure (by on-site inspection) the integrity of the enclosure or containment.
Set up procedures to control entry to and exit from the enclosure and/or area.
Supervise all employee exposure monitoring required by this section and
ensure that it is conducted as required by paragraph (f) of this section.
Ensure that employees working within the enclosure and/or using glove bags
wear respirators and protective clothing as required.
Ensure through on-site supervision, that employees set up and use,
engineering controls, use work practices and personal protective equipment
in compliance with all requirements
Ensure that employees use the hygiene facilities and observe the
decontamination procedures.
Ensure that through on-site inspection, engineering controls are functioning
properly and employees are using proper work practices.
Competent Person Training
Our competent person has received the following training for Classes I and II
asbestos work:
1. All aspects of asbestos removal and handling, including: abatement, installation,
removal and handling.
2. The contents of the asbestos rule.
3. The identification of asbestos.
4. Removal procedures where appropriate.
5. Other practices for reducing the hazard.
6. All PPE Requirements.
Our competent person has received the following training for Classes III and IV
asbestos work in addition to the above.
I.4.10
1. Aspects of asbestos handling appropriate for the nature of the work, to include
procedures for setting up glove bags and mini- enclosures.
2. Practices for reducing asbestos exposures.
3. Use of wet methods.
4. The contents of this standard.
5. The identification of asbestos.
This training includes successful completion of a course that is consistent with EPA
requirements for training of local education agency maintenance and custodial staff.
Regulated areas
Operations, where airborne concentrations of asbestos exceed or there is a
reasonable possibility they may exceed a PEL, are conducted within a regulated
area. All regulated areas shall be identified by the OSHA required signs and labels.
Demarcation
The regulated area is demarcated in a manner that minimizes the number of
persons within the area and protects persons outside the area from exposure to
airborne asbestos. When critical barriers or negative pressure enclosures are used,
they may demarcate the regulated area. Warning signs are posted stating the
particular hazard(s), as well as access requirements or limitations such as PPE
requirements.
Access
Access to regulated areas is limited to authorized persons and to persons authorized
by the OshAct or federal regulations.
Respirators
All persons entering a regulated area where employees are required to wear
respirators are supplied with an appropriate respirator. Third Party air monitoring
shall help identify the appropriate NIOSH approved respirator for the tasks.
Respirators will be provided at no cost to the employee per the Moreno Group, LLC
and Subsidiaries Respiratory Protection Program.
Prohibited Activities
We make sure that our employees do not eat, drink, smoke, chew tobacco or gum,
or apply cosmetics in a regulated area.
I4.11
Competent Persons
Our competent person will supervise all asbestos work performed within regulated
areas.
Communication of Hazards:
We understand the importance of communicating asbestos hazard information at
this job site, and will do so in all necessary manners. Areas where an asbestos
exposure hazard maybe present the regulated area shall be identified by signs and
labels that meeting the OSHA requirements.
Methods of Compliance
Our methods of compliance set operation-specific and exposure-triggered work
practices for conducting asbestos work. Each job is specific and the methods of
compliance will include the following required and optional procedures.
The following basic engineering controls and work practices are a part of all
asbestos operations at this jobsite regardless of the levels of exposure.
1) Vacuum cleaners equipped with HEPA filters to collect all debris and dust
containing ACM or PACM.
2) Wet methods, or wetting agents, to control employee exposures during asbestos
handling, mixing, removal, cutting, application, and cleanup, except where we
demonstrate that the use of wet methods is infeasible due to for example, the
creation of electrical hazards, equipment malfunction, and, in roofing.
3) Prompt clean-up and disposal of wastes and debris contaminated with asbestos
in leak-tight containers.
In addition to the requirements noted above for all asbestos operations we use the
following control methods to achieve compliance with the TWA permissible exposure
limit and excursion (STEL) limit.
Local exhaust ventilation equipped with HEPA filter dust collection systems.
Enclosure or isolation of processes producing asbestos dust.
Ventilation of the regulated area to move contaminated air away from the
breathing zone of employees and toward a filtration or collection device
equipped with a HEPA filter.
Wherever the feasible engineering and work practice controls described
above are not sufficient to reduce employee exposure to or below the
permissible exposure limit and/or excursion limit we will use them to reduce
employee exposure to the lowest levels attainable by these controls and shall
supplement them by the use of respiratory protection.
I.4.12
Prohibitions
We never use the following work practices and engineering controls for work related
to asbestos or for work which disturbs ACM or PACM, regardless of measured levels
of asbestos exposure or the results of initial exposure assessments:
High-speed abrasive disc saws that are not equipped with point of cut
ventilator or enclosures with HEPA filtered exhaust air.
Compressed air to remove asbestos, or materials containing asbestos, unless
the compressed air is used in conjunction with an enclosed ventilation system
designed to capture the dust cloud created by the compressed air.
Dry sweeping, shoveling, or other dry clean-up of dust and debris containing
ACM and PACM.
Employee rotation as a means of reducing employee exposure to asbestos.
Class I and II Requirements
All Class I and Class II work, including the installation and operation of the control
system is supervised by our competent person.
For all indoor Class II jobs, where we have not produced a negative exposure
assessment, or where during the job changed conditions indicate there may be
exposure above the PEL, or where we do not remove the ACM in a substantially
intact state, we will use adequate methods and practices to ensure that airborne
contaminates do not exit the regulated area.
Class III Requirements
We conduct Class III asbestos work using engineering and work practice controls
which minimize the exposure to our employees performing the work and to
bystander employees. We will use:
Wet methods.
When feasible, local exhaust ventilation.
Where the disturbance involves drilling, cutting, abrading, sanding, chipping,
breaking, or sawing of thermal system insulation or surfacing material we
will use impermeable dropcloths, and will isolate the operation using minienclosures or glove bag systems or another isolation method.
Where we do not have a "negative exposure assessment," or where
monitoring results show the PEL has been exceeded, we will contain the
area using impermeable dropcloths and plastic barriers or their equivalent,
or shall isolate the operation using another control system.
I4.13
I.4.14
Class II and III asbestos jobs where we do not conduct a negative exposure
assessment.
Class III jobs where TSI or surfacing ACM or PACM is being disturbed.
Selection criteria when employees are in regulated area where Class I work is
being performed, a negative exposure assessment of the area has not been
produced, and the exposure assessment of the area indicates the exposure
level will not exceed 1 f/cc as an 8-hour time weighted average, we provide
the employees with one of the following respirators:
(A) A tight-fitting powered air-purifying respirator equipped with high efficiency
filters;
(B) A full facepiece supplied-air respirator operated in the pressure demand
mode equipped with HEPA egress cartridges; or
(C) A full facepiece supplied-air respirator operated in the pressure demand
mode equipped with an auxiliary positive pressure self-contained
breathing apparatus. A full facepiece supplied-air respirator operated in
the pressure-demand mode equipped with an auxiliary positive pressure
self-contained breathing apparatus must be provided under such
conditions when the exposure assessment indicates exposure levels
above 1 f/cc as an 8-hour time weighted average.
Respirator Program
We have developed a respiratory protection program to satisfy the requirements of
an asbestos related project.
Respirator Fit Testing
We make sure that the respirator issued to each employee exhibits the least
possible facepiece leakage and that the respirator is fitted properly. We perform
either quantitative or qualitative face fit tests:
Before any of our employees are required to use any respirator with a
negative or positive pressure tight-fitting facepiece;
Whenever a different respirator facepiece (size, style, model, or make) is
used;
At least annually;
Whenever the employee reports, or our company, the physician or other
licensed health care professional (PLHCP), supervisor, or Program
Administrator makes visual observations of, changes in the employee's
physical condition that could affect respirator fit. Such conditions include, but
I4.15
are not limited to, facial scarring, dental changes, cosmetic surgery, or an
obvious change in body weight; and
When the employee, subsequently after passing a qualitative or quantitative
fit test, notifies the company, Program Administrator, supervisor, or PLHCP
that the fit of the respirator is unacceptable. That employee will be retested
with a different respirator facepiece.
See the Moreno Group, LLC and Subsidiaries Respiratory Protection Program for
Details.
Protective Clothing
We provide and require the use of protective clothing, such as coveralls or similar
whole-body clothing, head coverings, gloves, and foot coverings for:
Any employee exposed to airborne concentrations of asbestos that exceed
the TWA and/or STEL.
This site when a required negative exposure assessment is not produced.
Any employee performing Class I operations which involve the removal of
over 25 linear or 10 square feet of TSI or surfacing ACM and PACM.
Laundering
We ensure that laundering of contaminated clothing is done so as to prevent the
release of airborne asbestos in excess of the TWA or STEL.
Contaminated Clothing
Contaminated clothing is transported in sealed impermeable bags, or other closed,
impermeable containers, and be labeled.
Inspection of Protective Clothing
Our competent person examines work suits worn by our employees at least once
per work shift for rips or tears that may occur during performance of work. When rips
or tears are detected while an employee is working, they will be immediately
mended, or the work suit shall be immediately replaced.
Hygiene Facilities and Practices for Employees
Our hygiene facilities and practices requirements for this job are as required by
OSHA regulations.
Smoking in Work Areas
We ensure that employees do not smoke in regulated work areas where they have
increased potential for exposure to asbestos because of activities in that work area.
I.4.16
Housekeeping
Vacuuming
When we select vacuuming methods we always use HEPA filtered vacuuming
equipment. The equipment is used and emptied in a manner that minimizes the
reentry of asbestos into the worksite.
Waste Disposal
Asbestos waste, scrap, debris, bags, containers, equipment, and contaminated
clothing will be collected and disposed of in sealed, labeled, impermeable bags or
other closed, labeled, impermeable containers.
Care of Asbestos-Containing Flooring Material
Waste and debris and accompanying dust in an area containing accessible thermal
system insulation or surfacing ACM/PACM or visibly deteriorated ACM:
Is not dusted or swept dry, or vacuumed without using a HEPA filter.
Is promptly cleaned up and disposed of in leak tight containers.
Specifically:
We assess all asbestos operations for their potential to generate airborne
fibers.
Our designated competent person conducts an initial exposure assessment
immediately before or at the initiation of an operation to document expected
exposures, and that the assessment is completed in time to comply with
requirements triggered by exposure data or the lack of a "negative exposure
assessment."
We perform periodic monitoring and additional monitoring when required.
When required, we implement a medical surveillance program for all
employees when for a combined total of 30 or more days per year engage in
Class I, II, or III work or are exposed at or above the PEL, or when employees
are required to wear negative-pressure respirators.
We maintain objective data, monitoring, medical surveillance, training, and
building owner notification records when required and for the time periods
indicated in the asbestos rule.
Our asbestos competent person is qualified, authorized, and has the proper
training to ensure worker safety and health.
Our respirator program is in place.
I4.17
Our Class I, II, and III asbestos work, and all other operations where airborne
concentrations of asbestos exceed or there is a possibility the may exceed a
PEL, are conducted within regulated areas.
We understand that the communication of asbestos hazards is vital to prevent
further overexposure and that we have specific duties under the asbestos rule
to communicate those hazards through written notifications, signs, labels and
employee information and training.
Multi-employer worksites
We Will:
Inform other employers on the site of the nature of our work through SH&E
Meetings and/or Site Orientations.
Relay information of the existence of regulated areas.
Take correct measures to ensure personal working adjacent to regulated
areas are removed from the affected area until any breach within the
containment is repaired or perform an initial exposure assessment is
performed per OSHA 1926.1101(f).
I.4.18
Page 1 of 4
Original: 05/06/2003
Revised: 02/01/2010
I5.1
Do not twist or turn your body once you have made the lift.
Bend at the knees to set the load down.
Minimize the amount of lifts as much as possible.
Alternative Lifting Methods
For objects that exceed 75 pounds, or for any awkward (i.e. not proportional)
or long loads (extends beyond ones body), the following methods should be
utilized to be prevent possible injuries:
Utilizing two or more employees for a lift. It is critical that whenever
multiple employees are involved in a single lift, everyone
communicates to each other, and the load is balanced out between the
employees.
Mechanical lifting devices (Cranes, forklifts, dollies, chain falls, comea-longs, etc.) should be utilized for loads exceeding the RWL per
employee.
I5.3
Load Chart
Load
Can of Welding Rods
Welding Wire Spool
Fluxcore feeder without wire
Fluxcore feeder with wire
Roll of submerged arc wire
1 foot 6 XX pipe
1 foot 4 schedule 80 pipe
1 foot 4 XX pipe
1 foot 2 schedule 80 pipe
1 foot 2 XX pipe
1 foot 8 schedule 80 pipe
1 foot 12 x50 I-beam
1 foot 4 x 13 I-beam
1 foot 6 x 25 I-beam
1 foot 6 x 15 I-beam
20 joint handrail pipe
Steel Grating (1)
6 600 pound flange
4 150 pound flange
8 Foot Section Handrail (3
posts)
3 x 20 x 1 Sheet of Grating
5 gallon bucket paint
2.5 gallon pale of zinc powder
Paint Pot empty
Paint Pot with Paint
Blasting sand in bag
1 k tugger
Scaffold Board
Aluminum Peg Board 20
Aluminum Peg Board 12
50 foot of welding lead
6 ton chain fall (Jet)
3 ton chain fall (Budgit)
12 ton snatch block
6 ton Come-A-Long
35 Ton Shackle
55 Ton Shackle
Mag drill
Sheet of plywood
Beam Clamp
Tripod
Pipe Jack
I5.4
Estimated Weight
50 pounds
44 pounds
30 pounds
74 pounds
60 pounds
54 pounds
15 pounds
40 pounds
5 pounds
9 pounds
44 pounds
50 pounds
13 pounds
25 pounds
15 pounds
55 pounds
7.34 pounds per ft2
73 pounds
16.5 pounds
120 pounds
440 Pounds
75 pounds (Average)
100 pounds
58 pounds
88 pounds
100 pounds
120 pounds
20 pounds
130 pounds
70 pounds
60 pounds
55 pounds
80 pounds
55 pounds
60 pounds
45 pounds
90 pounds
40 pounds
50 pounds
45 pounds
35 pounds
18 pounds
Benzene Procedure
Page: 1 of 6
Original: 01/01/2005
Revised: 01/01/2007
Benzene Procedure
Purpose
The purpose of this standard is to communicate to employees the potential hazard
when exposed to Benzene and to establish uniform procedures to be followed by
Moreno Group LLC and Subsidiaries employees for benzene exposures. It is based
on 29 CFR 1910.1028 requirements.
Scope
Moreno Group LLC and Subsidiaries employees may be potentially exposed to
benzene while working at a host contractor facility or while working on pipelines and
around crude oil. As part of the Hazard Communication standard and other
regulations under, such as Process Safety Management, the Host Company will
relay the potential exposure information to management officials prior to start of the
job.
Responsibilities
The Facility Manager / Site Manager or Designee is responsible for
Understanding and complying with the requirements of this procedure.
Ensuring that personnel with potential exposures to benzene are placed
within a medical surveillance program that includes respiratory protection and
trained.
Ensure that all work activities and documentation of this program is kept onsite during the course of activities with potential exposures to benzene.
Ensuring that personnel performing benzene monitoring at work locations are
trained in the use of monitoring equipment.
Auditing compliance with this procedure.
The First Line Supervisor or Designee is responsible for:
Understanding and complying with this procedure.
Conferring with Facility / Site Manager or designee or SH&E Department as
to any potential benzene exposure.
I6.1
I6.2
I6.3
Precautions
All employees must realize the hazard of benzene and acquire a thorough
knowledge of this poisonous material. Moreno Group LLC and Subsidiaries and / or
host facility will conduct air monitoring to determine the concentrations of benzene
routinely present or where it may be present, and for those areas that exceed the
OSHA PEL, establish regulated work areas - designed to control who enters the
area and what types of protective equipment are required. Extreme care must be
used when working in regulated areas or on piping or equipment, such as operating
any valve, line, bleeder, etc., which may contain benzene. Where benzene is
present, engineering controls such as isolation, or administrative controls will be
utilized first to protect the workers. In certain circumstances, however, personal
protective equipment may be required. This has been addressed in the chapter of
this manual for PPE, and may require respirators, protective clothing, eye, face, and
splash protection, etc.
Monitoring
The presence of benzene may be determined with portable detection devices that
are available for use. These devices will primarily include direct reading instruments,
such as Draeger colorimetric tubes and pump, or others that are available through
equipment rental agencies.
These detection devices are available by contacting the Facility Manager or
Designee, and / or the SH&E Department. In addition, our consultant AESI or
another third party to determine the concentration of benzene that may be present
during certain operations may conduct air monitoring for exposure assessment.
These records will be kept in accordance with OSHA regulations
Based on exposure monitoring results, Moreno Group LLC and Subsidiaries will
develop and implement engineering and I or work practice plan to minimize
exposures. This plan will be developed and maintained by the Facility Manager or
Designee, Human Resources and Safety, Health and Environmental Department.
The plans will be reviewed and revised as necessary and appropriate based on the
most recent exposure monitoring data.
Monitoring Devices
Portable Benzene Detection Devices
These devices may be used when fixed systems are not adequate or not present.
These units will be rented from Total Safety, Inc. or another vendor, and will give an
audible alarm at a pre-determined level of benzene, usually 0.5 ppm. They are
maintained and calibrated before each use by the Rental Company or the Safety
Supervisor, which will use a calibration gas.
Medical Monitoring
Moreno Group LLC and Subsidiaries employees who are exposed at or above the
Action Level of 0.5 ppm for 30 or more days per year, medical monitoring is provided
I6.4
free of charge. Moreno Group LLC and Subsidiaries Approved Medical Facilities will
be provided a copy of the OSHA standard. These facilities will perform medical
examinations and tests to monitor the health of Moreno Group LLC and Subsidiaries
employees during the time they have a potential for an exposure at or above the
Action Level.
Training
The host facility will be responsible for providing site specific training to our
personnel. In addition to the host facility site specific training, Moreno Group LLC
and Subsidiaries will also train our employees as to the hazards of benzene during
our Hazard Communication training and prior to any potential exposure to benzene.
As part of employee training for each job, this information will be relayed to our
employees, so they are aware of the location and hazards associated with benzene,
as well as methods used to reduce or control exposures.
At host facilities, regulated areas are established where the PEL can or may be
exceeded. A detailed copy of the OSHA regulation governing benzene can be
reviewed by any employee or their designated representative in the Site Office,
available from the Facility / Site Manager or designee, and / or the SH&E
Department. This is also the source for additional exposure information and other
pertinent written plans and programs
Personal Protective Equipment (PPE) and Respiratory Protection
The level of Personal Protective Equipment (PPE) shall be determined during the
initial job planning process and/or during the development of the task Job Safety and
Environmental Analysis (JSEA). PPE may include but not limited to Chemical
Goggles, Face Shield, Aprons, Chemical Suits, Chemical Gloves and Chemical
Boots.
Respiratory protective equipment is to be utilized when exposed to hazardous
concentrations of benzene. Only approved respiratory protection will be used. For
exposures up to 10 ppm, half face air purifying respirators with organic vapor
cartridges (black) can be used. Supplied air respiratory equipment, such as airline
respirators with escape bottles or self-contained breathing apparatuses (SCBAs)
shall be utilized for escape or emergency conditions. Refer to the Moreno Group
LLC and Subsidiaries Respiratory Protection Program within our SH&E Management
System Manual for additional information.
No one is permitted to wear a respirator unless they have been properly trained, fittested, and received medical clearance, and only NOISH-certified respirators can be
used.
Evacuation I Escape I Emergency Procedures
Prior to entry on to the site where benzene may be present, check with the owner I
operators to determine what their specific emergency plans address and always
I6.5
follow their requirements. They may assign a coordinator to assist with these
matters.
Whenever an unsafe level of benzene is detected, do not panic. The following
escape method will be followed:
1. Put on a 5 minute escape air pack (if available).
2. Evacuate cross wind then upwind of the emission to a safe area.
3. Alert others of hazard.
4. Call your supervisor from a safe area. Stand by in safe area for instructions from
your supervisor and return to work area only when it has been determined that it
is safe to return.
Equipment Opening
Maintenance
Anytime process equipment, i.e., piping, vessels, instruments, drain lines, blinds,
etc., which may contain benzene is entered or opened in any area, or if work is to be
performed where benzene may be present, those involved must wear the
appropriate level of Personal Protective Equipment and Respiratory Protection while
performing the work. All line opening or equipment opening shall be performed in
accordance of our line opening procedures.
I6.6
Bloodborne Pathogens
Page: 1 of 9
Original: 06/08/1998
Revised: 05/01/2008
Bloodborne Pathogens
Purpose
Moreno Group LLC and Subsidiaries seeks to limit employee exposure to blood and
other infectious materials in compliance with OSHA 29 CFR 1910.1030. This
program identifies those employees who are occupationally exposed, and addresses
both the means by which the exposure can be reduced or eliminated and the
procedure for evaluating an exposure incident.
Scope
Safety, Health and Environmental Department Representatives, depending upon
their work assignments, may be occupationally exposed to bloodborne pathogens
including human immunodeficiency virus (HIV) and the Hepatitis B Virus (HBV). The
Occupational Exposure to Bloodborne Pathogens Standard (29 CFR 1910.1030)
addresses this risk and aims to reduce occupational exposure.
Responsibilities
The Facility Manager / Offshore Manager or Designee is responsible for:
Understanding and complying with the requirements of this procedure.
Ensuring that personnel are informed of bloodborne pathogen safeguards.
Offering Hepatitis B Vaccine (HBV) to all personnel whom may be exposed.
Auditing compliance with this procedure.
The First Line Supervisor / Offshore Superintendent is responsible for:
Understanding and complying with this procedure.
Conferring with Facility Management or SH&E Department as to any
possible bloodborne pathogen exposure
Advising Facility Management of any suggestions to improve the
Bloodborne Pathogen Procedure.
The Safety, Health and Environmental Department is responsible for:
Understanding and complying with this procedure.
I7.1
I7.2
Universal Precautions
All blood and certain body fluids are to be treated as if they are infectious for HIV,
HBV, or any other bloodborne pathogen. This method of infection control, known as
Universal Precautions, will be utilized in any situation that involves potential
exposure to blood or other potentially infectious materials.
Engineering Control
Engineering Controls, methods of isolating or removing a hazard from the
workplace, are one of the most effective methods of hazard reduction. Engineering
controls should be employed first and, if the hazard remains, personal protective
equipment will also be used. Engineering controls include the use of sharps
disposal containers, disposable airway equipment or resuscitation bags, and pocket
mouth-to-mouth resuscitation devises for CPR. These controls should be examined
and maintained or replaced on a regular schedule to ensure their effectiveness.
Work Practices
Methods that reduce the exposure during a task or procedure will be used to
minimize exposure. Hands and other skin surfaces, which come in contact with
blood or other potentially infectious materials, must be washed immediately with
soap and water. In the event that running water is unavailable, antiseptic towelettes
may be used. Hands will be washed with soap and water as soon as possible.
Contaminated needles and sharps will be disposed of into a sharp container without
recapping. Sharps may only be recapped using a one-handed technique in
emergency situations.
Puncture coded, resistant, color and leak proof containers will be utilized for disposal
of contaminated sharps.
Eating, drinking, smoking, applying cosmetics, and handling contact lenses is
prohibited in areas where exposure is likely to occur.
Food and drink will not be stored in or on refrigerators, cabinets, shelves, or counter
tops where blood or other potentially infectious materials are present.
All procedures involving blood or potentially infectious materials shall be handled in
a way which minimizes splashing, spraying, and spattering.
Specimen containers for blood or other potentially infectious materials will be placed
in leak-proof and puncture resistant containers and labeled with the appropriate
biohazard label.
I7.3
Labels/Signs
Biohazard warning labels of florescent orange or orange-red letters, identified in the
appendix, will be used to identify blood or other potentially infectious materials.
Color-coded red containers. or bags may be used in place of labels. Specifics on
labeling requirements can be found in the appendix.
Personal Protective Equipment
Personal protective equipment will be utilized at all times to prevent contaminated
materials from passing to the employee's clothing, skin, eyes, mouth or mucous
membranes. Latex gloves are provided and will be worn when contact with the
hands is anticipated. Gloves will be disposed of in the appropriate container after
use. Masks, goggles, and face shields will be worn whenever splashing, spraying,
or splattering is anticipated. Gowns, aprons, and other protective clothing should be
used if a large contamination is possible.
All personal protective equipment is to be removed when leaving the work area or
emergency scene and disposed of in an appropriate container.
Regulated Waste
All contaminated items including sharps, disposable linens, disposable equipment,
broken glass, and disposable personal protective equipment are considered
regulated waste.
All contaminated sharps will be placed in closeable, puncture resistant, leak proof
and color-coded containers.
All other regulated waste and full sharps containers will be placed in a regulated
waste container for disposal in accordance with local, state, and federal regulations.
Records Will be kept as required.
Contaminated Laundry
Disposable linens including sheets, pillowcases, and towels will be used to eliminate
the need for laundering. Contaminated items will be placed in a regulated waste
container as specified in the section on Regulated Waste.
Housekeeping
All contaminated reusable equipment, work surfaces, and environmental areas will
be cleaned as soon as possible with an appropriate disinfectant such as a 1 to 10
concentration of bleach to water. Instruments, which may rust, may be placed in an
appropriate solution such as Cidex for disinfecting.
Appropriate personal protective equipment will be worn during decontamination
procedures.
I7.4
"No Exposure"
Supervisor needs to document in local files the information related to the incident.
If the preliminary assessment of the incident indicates a "Potential Exposure" or a
defined "Exposure Incident" occurred, the exposed employee must be offered
Hepatitis B Vaccination series, as a post-exposure preventative, within 24 hours of
the incident, unless the employee has previously received the complete Hepatitis B
Vaccination series; or Antibody testing has revealed that the employee is immune; or
the vaccination is not advised for medical reasons.
Employee will complete a "Consent" or "Declination" form depending on acceptance
choice.
Hepatitis B Vaccination program will be administered by a licensed, registered
nurse, or licensed physician knowledgeable of the bloodborne pathogens standard.
"Exposure Incident"
If it is determined by management or a medical professional that a defined
"Exposure Incident" has occurred, then a confidential medical evaluation and followup of the incident will be made by a physician or Safety Coordinator.
Medical counseling will be made available to any employee who has been exposed.
Request for clinical evaluation and testing will be referred to the companys
physician.
Awareness Sessions
During the New Employee Orientation / SH&E Training, new employee will receive
awareness information on preventive controls and procedures for avoiding contact
with bloodborne pathogens.
Recordkeeping
Moreno Group LLC and Subsidiaries will retain all records associated with this
guideline including employee training, hepatitis B vaccination documentation and
post exposure medical records.
The Human Resource Department shall maintain all medical records. These records
will be maintained in a confidential manner for the duration of employment plus 30
I7.6
I7.7
Attachment 1
I7.8
Facility Manager.
RE:
Hepatitis Vaccine
DO NOT DISCARD THIS FORM
ROUTE TO OPERATIONS DEPARTMENT.
ON COMPLETION OF VACCINATION PROCESS
Thank you for making one of the most important decisions of your
career! This vaccine will offer you protection from Hepatitis B for about
five years. After that time you should consider getting an antibody test
since the exact length of effective immunization is not currently known.
Please follow these instructions for your current vaccination.
1.
2.
3.
4.
BY:
INJECTION 2: DATE:
BY:
INJECTION 3: DATE:
BY:
I7.8.a.1
Attachment 2
I7.9
HEPATITIS B VACCINATION
DECLINATION FORM
An employee who chooses not to accept the vaccine must sign the following
statement of declination of hepatitis B vaccination. This statement can only be
signed by the employee following appropriate training regarding hepatitis B, hepatitis
B vaccination, the efficacy, safety, method of administration, and benefits of
vaccination, and that the vaccine and vaccination are provided free of charge to the
employee. The statement is not a waiver; employees can request and receive the
hepatitis B vaccination at a later date if they remain occupationally at risk for
hepatitis B.
DECLINATION STATEMENT
Employee Signature
Witness Signature
Date Signed
Date Signed
I7.9.a.1
Cadmium Protection
Page: 1 of 15
Original: 01/01/2007
Revised: 05/01/2008
Cadmium Protection
Purpose
The purpose of this program is to establish and implement practices and procedures
for protecting the health of Moreno Group LLC and Subsidiaries employees who
may be exposed to Cadmium on the job. This program also establishes methods for
complying with the OSHA Construction Industry Cadmium Standard, 29 CFR
1926.1127, 29 CFR 1910.1027.
Scope
The scope of this program applies to all Moreno Group LLC and Subsidiaries
projects and employees involved with potential Cadmium/Cadmium compound (Zinc
Galvanized) exposure when such work involves construction, alterations, and
repairs. The activities include, but are not limited to, wrecking, demolishing, and
salvaging structures where cadmium or cadmium-containing materials are present;
cutting, brazing, grinding, or welding (Flux on welding rods can contain cadmium
compounds), on surfaces that are painted with cadmium-containing paints (usually
high-heat pipes or vessels); and transporting, storing, and disposing of cadmium or
cadmium-containing materials on the site or location where construction activities
are performed.
Cadmium coatings are sacrificial corrosion protection coatings widely used on steel
and aluminum especially when exposed to alkaline and salt water environments.
They also possess a very low coefficient of friction and low electrical resistivity which
makes them ideal for corrosion protection coatings on threaded fasteners or
electrical connectors. These are most often used in critical or safety related
applications in the aerospace, electrical connector, defense, mining, nuclear, and
off-shore oil and gas industries.
This program also applies to all subcontractors, working under the direct control of
Moreno Group LLC and Subsidiaries, involved with Cadmium/Cadmium Compound
projects and activities. Subcontractors must provide all manpower, supplies,
equipment, training, and medical examination and testing necessary to comply with
this program.
Responsibilities
The Facility Manager/Site Manager/Yard Foreman or Designee is responsible for:
Informing the SH&E Department of the any upcoming project that may have
the potential of containing Cadmium.
.
I8.1
Inform any subcontractors that may be working on the project that the project
contains Cadmium.
Ensure that subcontractors understand and comply with this policy as well as
the Cadmium Employee Project Specific Protection Plan.
The First Line Supervisor is responsible for
Understanding and complying with this policy/ procedure as well as the
Cadmium Employee Project Specific Cadmium Protection Program.
Designating employees for the project and ensuring that those employees all
go to the Human Resources Department to get an authorization to go to the
Medical Review Officer and receive initial blood Cadmium levels prior to
performing any work on the project.
Coordinate with the SH&E Department to see if all designated employees
have received Cadmium training and or up to date. If training is needed
coordinate with the SH&E Department date and time for which training will
take place.
Ensuring that barricade and applicable warning signs have been posted prior
to the startup of the project.
Ensuring that all safety measures are being followed throughout the project.
Performing with the SH&E department the Cadmium Job Checklist and
performing this checklist throughout the project.
Coordinating with the Human Resources Department at the end of the project
or when any employee is removed from the project that those employees all
go to the Medical Review Officer and receive blood Cadmium levels.
The Safety, Health and Environmental Department is responsible for
Coordinating paint samples to have analyzed to determine if project contains
Cadmium.
Informing Facility Manager/Offshore Manager/Yard Foreman or designee of
the outcome of the sample analysis.
Perform any Cadmium training, any respiratory training and fit testing for all
employees that need this training.
Coordinating and performing any air monitoring which may be required.
Developing Cadmium Employee Project Specific Protection Plan.
I8.2
Warning signs
Hygiene facilities and practices
Protective work clothing and equipment
Respiratory protection
Housekeeping
During the period that respirators are worn, the protection factor of the specific
respirator may be used to determine employees exposure to airborne Cadmium and
to achieve compliance with the PEL. The protection factors listed in the respirator
selection table of Moreno Group LLC and Subsidiaries Respiratory Protection
Program. For example:
Measured airborne Cadmium concentrations at the workers breathing zone:
30 g/m ,8-hour TWA
Half-mask, air-purifying, negative pressure respirator with HEPA filters worn
all day: protection factor of 10
Employees daily Cadmium exposure: 3 g/m
Authorized Person
All work activities where employee airborne Cadmium exposures may exceed the
Action Level will include an Authorized person in both the planning and performing
stages of projects involving Cadmium exposure.
The Authorized person will be a person with training and experience in construction
jobs involving Cadmium exposure. The Authorized person will have the capability of
identifying hazards and the authority to take immediate action to eliminate them.
The Authorized person will be at the work site at all times while Cadmium exposure
activities are in progress. They may have other job duties, but must be able to
monitor work continuously for hazards or deficiencies, and the authority to take
immediate corrective action.
Employee Information and Training
All employees who work on projects where airborne Cadmium exposures are known
to or expected to be at or above the Action Level will be provided information and
training on the hazards of Cadmium and measures for controlling these hazards and
protecting health.
Employees will receive initial comprehensive Cadmium training before performing
work that may involve airborne Cadmium exposure. This training will be repeated
I8.5
annually as a refresher course. Training records will indicate employees name, date
of the training and name of the person who conducted the training. Training records
will be kept minimum 1 year.
The content of Cadmium training will include:
The specific nature of activities or operations that may result in airborne
Cadmium exposure above the Action Level
The health effects and risks of Cadmium exposure
OSHA standards and guidelines for Cadmium exposure
Engineering controls, including containments and ventilation systems
Work practices for controlling Cadmium exposure, including information,
warning signs, housekeeping, protective clothing and proper hygiene facilities
and practices
Respiratory protection for controlling Cadmium exposure, including fit testing
Methods for monitoring airborne Cadmium concentrations and exposures
The medical surveillance program including medical removal
Precautions for female employees who are pregnant.
Instructions to employees that chelating agents should not be used to remove
Cadmium from their bodies
When conducting Cadmium exposure activities on a multi-employer work site,
Moreno Group LLC and Subsidiaries will notify other employers of the nature of the
Cadmium exposure system in effect, and the potential need to take measures to
protect their employees. Notification to other employers will contain the following:
NOTICE - MORENO GROUP LLC AND SUBSIDIARIES IS PERFORMING
ACTIVITIES AT THIS JOB SITE THAT MAY CREATE AIRBORNE CADMIUM
DUST. ALL CONTRACTORS AT THIS JOB SITE SHALL REMAIN CLEAR OF
ANY CADMIUM EXPOSURE AREA. ACCESS INTO CADMIUM EXPOSURE
AREA IS CONTROLLED BY THE MORENO GROUP LLC AND SUBSIDIARIES
JOB FOREMAN. ONLY TRAINED, QUALIFIED WORKERS ARE PERMITTED TO
ENTER CADMIUM EXPOSURE AREAS AND MUST WEAR RESPIRATORS AND
PROTECTIVE CLOTHING.
Medical Surveillance
All employees who may be exposed to Cadmium at or above the Action Level for 30
or more days per year; or who may be required to wear a respirator will be provided
initial and periodic medical examinations.
I8.6
All employees who may be exposed to Cadmium at or above the Action Level for 30
or more days per year will be provided with initial and periodic biological monitoring
in the form of blood and urine sampling and analysis of Cadmium levels and Beta-2microglobulin in urine (B(2)-M), a low molecular weight protein.
All employees who are temporarily removed from Cadmium exposure due to
elevated blood Cadmium levels or at the recommendation of a physician may be
reassigned other job duties at the site that do not involve exposure to Cadmium
above the Action Level.
The specific components, requirements, and frequencies of medical examination,
blood Cadmium test, and medical removal protection benefits are provided in
Moreno Group LLC and Subsidiaries Medical Surveillance / Examination Program
for Cadmium Exposure and Respirator Use (see Attachment 1)
Warning Signs
Warning signs will be posted in the work area around activities where Cadmium
exposures may exceed the Permissible Exposure Limit. The work area can be
demarcated by Yellow Warning Tape.
Signs will be posted at every accessible side of the work area. These signs will be
easily visible from a distance so that employee can read the sign and take
necessary protective measures before entering the work area. Signs will read as
follows: DANGER, CADMIUM CANCER HAZARD CAN CAUSE LUNG AND
KIDNEY DISEASE, AUTHORIZED PERSONNEL ONLY, RESPIRATORS
REQUIRED IN THIS AREA.
The Authorized person will control access of persons into work area.
All persons entering work areas will wear protective clothing and respirators.
Eating, drinking, smoking, and chewing is prohibited in work areas and any area
where Cadmium exposure may exceed the Permissible Exposure Limit.
Containments
Where required by federal, state, or local regulation, the project sponsor, or the
project owner, containments will be constructed and used as specified.
The purpose of containments is to restrict or prevent the spread of Cadmiumcontaining dust or debris to surrounding areas or the environment. While the proper
use of containments can help protect the public and the environment, they generally
cause a significant increase in airborne Cadmium concentrations in the work area.
Containments may increase the potential for higher employee Cadmium exposures.
Therefore, the use of well designed exhaust ventilation and the use of more
protective respirators may be necessary to properly protect workers.
I8.7
Protective clothing will include washable or disposable full body coveralls. Other
protective equipment will include faceshields, hats, gloves, shoes or disposable shoe
covers, eye protection, and hearing protection as appropriate.
Disposable protective clothing will be used for no more than one (1) work day. They
will be disposed of as Cadmium-contaminated waste.
Reusable coverall will be collected at the end of each work day in closed containers.
Contaminated clothing will be cleaned by authorized laundries according to all
applicable federal, state, or local regulations pertaining to Cadmium-contaminated
laundry and water discharge. All containers of Cadmium-contaminated laundry will
be labeled as follows: CAUTION: CLOTHING CONTAMINATED WITH CADMIUM.
DO NOT REMOVE DUST BY BLOWING OR SHAKING. DISPOSE OF CADMIUM
CONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL,
STATE OR FEDERAL REGULATIONS.
Reusable protective clothing (coveralls) worn where the exposure was above the
action level, will be laundered at least weekly, and clean coveralls provided daily to
employees
Protective clothing and equipment will be removed in the contaminated section of
the change area and will not be worn into any clean areas not contaminated with
Cadmium.
Protective clothing and equipment will be worn by all employees performing the
following activities where Cadmium-containing compounds are present unless
exposure monitoring proves otherwise: When abrasive blasting, cleanup of
expendable abrasives, abrasive blasting enclosure construction, movement and
removal, power tool cleaning with and without dust collection systems, manual
scraping, manual sanding, manual demolition of structures, heat gun applications,
welding,
cutting,
torch
burning,
chemical
stripping
and
Cadmium
contamination/emergency clean-up activities.
Emergency situations
In the event of emergency situations involving substantial releases of airborne
cadmium, the use of appropriate respirators and personal protective equipment will
be utilized. In addition, employees not essential to correcting the emergency
situation shall be restricted from the area and normal operations halted in that area
until the emergency is abated. Emergency plans shall be noted on Project Specific
Requirements (Attachment 2).
Respiratory Protection
Respiratory protection will be used in combination with engineering controls and
work practices to maintain employee airborne Cadmium exposures below the
Permissible Exposure Limit.
I8.9
I8.10
Respirator Required
mask air purifying respirator with
HEPA filters2,3
mask supplied air respirator
operated in demand (negative
pressure mode.)
Loose fitting hood or helmet
powered air-purifying respirator
with HEPA filters.3
Hood or helmet supplied air
respirator operated in continuous
flow mode that is type CE abrasive
blasting respirators operated in
continuous flow mode.
Respirator Required
Exposure Monitoring
For each work project, personal air samples will be collected to determine airborne
Cadmium exposures to employees performing tasks involving Cadmium exposure.
Full shift (at least 7 hours) air samples will be collected for each job classification in
each work area. The air samples will be taken for the shift with the highest expected
exposure level. Moreno Group LLC and Subsidiaries will implement employee
protective measures until results of the employee exposure assessment are
received. The Authorized person will be responsible to ensure that exposure
monitoring is performed.
Where initial monitoring indicates that Cadmium exposures are below the Action
Level, and where work activities and conditions will remain the same as at the time
of initial sampling, additional monitoring need not be repeated for that work project.
A written record of the air monitoring data will be kept at the job site.
Where initial monitoring indicates that Cadmium exposures are at or above the
Action Level but at or below the PEL, additional representative exposure monitoring
will be conducted at least once every six (6) months for that work project. Where
initial monitoring indicates that Cadmium exposures are above the PEL, Moreno
Group LLC and Subsidiaries shall include in the written notice a statement that the
PEL has been exceeded and a description of the corrective action being taken by
the employer to reduce employee exposure to or below the PEL.
Additional monitoring shall be conducted whenever there has been a change in the
raw materials, equipment, personnel, work practices, or finished products that may
result in additional employees being exposed to cadmium at or above the action
level or in employees already exposed to cadmium at or above the action level being
exposed above the PEL, or whenever the employer has any reason to suspect that
any other change might result in such further exposure.
All air samples will be collected and analyzed according to NIOSH 7082 Method or
equivalent. All samples will be analyzed by laboratories accredited under the
Laboratory Accreditation Program of the American Industrial Hygiene Association for
metals analysis.
All exposed employees will be notified in writing of the monitoring results within five
(5) days after receiving these results.
Initial exposure monitoring may not be required when previously collected data has
conclusively determined that current job condition exposure levels will be less than
the Action Level.
Housekeeping
Accumulations of Cadmium-containing dust and debris generated by work activities
will be removed and cleaned daily.
All persons doing the clean-up will be trained in performing Cadmium activities,
respirator qualified, and participate in the medical surveillance program. Respirators
I8.12
and protective clothing will be worn by all persons doing the cleanup unless
exposure monitoring proves otherwise.
Wherever feasible, HEPA-filtered vacuum cleaners will be used for housekeeping.
All Cadmium-containing dust and debris will be collected into sealed containers.
The waste will be tested to determine whether it will be disposed as hazardous or
non-hazardous waste. Containers will be labeled as follows: DANGER CONTAINS
CADMIUM, CANCER HAZARD, AVOID CREATING DUST, CAN CAUSE LUNG
AND KIDNEY DAMAGE
Employees will not be permitted to remove Cadmium-containing dust from protective
clothing or equipment by blowing, shaking, or by any other means which disperses
Cadmium in the air.
Project Specific Requirements
The specific worker Cadmium protection requirements for each Cadmium-removal
project will be determined by Moreno Group LLC and Subsidiaries, the project
sponsor, and the project owner. The job specific requirements will be placed in
Attachment 2 - Cadmium Removal Project Specific Requirements. Enough detail
will be provided as to accurately outline the job specific requirements. This
attachment will be posted at the job site and maintained with the work records of the
project.
Recordkeeping
All records relating to training, medical examinations, blood Cadmium monitoring,
exposure monitoring, and project specific requirements will be maintained by
Moreno Group LLC and Subsidiaries, for the employees length of employment plus
30 years.
Other Relevant Information
The compliance program will be kept available at the work site for examination by an
affected employee or authorized person/agency.
The compliance program will be revised and updated at least annually.
I8.13
Attachment 1
I8.14
I8.14.a.2
Recent Examination
An initial examination is not required to be provided if adequate records show that
the employee has had an Initial Exam as outlined above within the past 12 months.
In that case, such records shall be maintained as part of the employee's medical
record and the prior exam shall be treated as if it were an initial examination.
Periodic Examinations
For currently exposed employees, who are subject to medical surveillance under
29CFR1910.1027 (l)(1)(i)(A), Moreno Group LLC and Subsidiaries shall provide the
minimum level of periodic medical surveillance which consists of periodic medical
examinations and periodic biological monitoring. A periodic medical examination
shall be provided within one year after the initial examination and thereafter at least
biennially. Biological sampling shall be provided at least annually, either as part of a
periodic medical examination or separately as periodic biological monitoring.
Periodic Medical Exams will include the following:
A detailed medical and work history, or update thereof, with emphasis on:
past, present and anticipated future exposure to cadmium; smoking history
and current status; reproductive history; current use of medications with
potential nephrotoxic side-effects; any history of renal, cardiovascular,
respiratory, hematopoietic, and/or musculo-skeletal system dysfunction; and
as part of the medical and work history, for employees who wear respirators,
questions 3-11 and 25-32 in Appendix D;
A complete physical examination with emphasis on: blood pressure, the
respiratory system, and the urinary system;
A 14 inch by 17 inch, or a reasonably standard sized posterior-anterior chest
X-ray (after the initial X-ray, the frequency of chest X-rays is to be determined
by the examining physician);
Pulmonary function test of forced vital capacity and forced expiratory volume.
Tests for blood pressure and resting heart rate.
Blood sample and analysis for Cadmium level; Cadmium in urine (CdU),
standardized to grams of creatinine (g/Cr); Beta-2 microglobulin in urine
(B(2)-M), standardized to grams of creatinine (g/Cr), with pH specified, as
described in Appendix F of the standard; and Cadmium in blood (CdB),
standardized to liters of whole blood (lwb).
Blood analysis, in addition to the analysis required under paragraph
(l)(2)(ii)(B), including blood urea nitrogen, complete blood count, and serum
creatinine;
I8.14.a.3
I8.14.a.4
I8.14.a.5
I8.14.a.6
I8.14.a.7
Attachment 2
I8.15
_________________________________________________________________
I8.15.a.2
___________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
EMERGENCY PLANS ______________________________________________________
_________________________________________________________________________
_________________________________________________________________________
CONSTRUCTION CONTRACTS/PURCHASE ORDERS
__________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
I8.15.a.3
Fitness to Work
Page: 1 of 11
Original: 01/01/2006
Revised: 02/01/2010
Fitness to Work
Purpose
The purpose of this standard is to assure that employees are and remain able to
safely perform the essential functions of their jobs and arises out of concern that an
employee may have a health problem which could impact his or her ability to safely
and environmentally friendly perform the essential functions of his or her job and to
establish requirements and recommendations related to employee fitness to
continue work under such circumstances or return to work after illness or injury
which can reasonably be anticipated to affect the employees ability to perform the
essential functions of his or her job. This standard is intended to further both
offshore and onshore safety while complying with all state and federal laws such as
the Family Medical Leave Act and Americans with Disabilities Act.
Scope
The scope of this program describes the implementation of Moreno Group LLC and
Subsidiaries Fitness to Work Evaluations. The Fitness to Work Evaluations will
include both salary and hourly employees.
Responsibilities
The Facility Manager / Offshore Manager or designee is responsible for:
Understanding and complying with the requirements of this procedure.
Ensuring that personnel are informed of Moreno Group LLC and Subsidiaries
Fitness to Work Evaluations.
Verifying need for Fitness to Work when the employee has taken prescription
medicine or experienced an off the job injury, accident or sickness which can
reasonably be anticipated to affect the employees ability to perform the
essential functions of his or her job.
Informing the Human Resource Department of an employees need for a
Fitness to Work Evaluation under this program.
Consulting with the Human Resource Department and / or the SH&E
Department as necessary concerning employees taking prescription
medicine.
Approving or disapproving of work that exceeds the 2-hour extension or 3
consecutive days limits.
I9.1
I9.2
Return to Work
Before an employees return to work following any substantial illness, injury or
absence (but not limited to fractures to bones, back injuries, sprains, significant car
accidents, heart attack, etc.) which can reasonably be anticipated to affect the
employees ability to safely perform the essential functions of his or her job.
Overseas Assignments
Before an employee may accept an overseas assignment, they must first be
evaluated by the Company Physician to ensure the employees health is acceptable
for an overseas assignment.
Upon passing the physical for their overseas assignment, the employee will be
required to start the appropriate Immunizations for the country they will be traveling
to and working. These vaccines are recommended to protect travelers from illnesses
present in other parts of the world and to prevent the importation of infectious
diseases across international borders.
Vaccinations needed depends on a number of factors including destination, whether
our employees will be spending time in rural areas, the season of the year, the
employees age, the employees health status, and previous immunizations.
The vaccinations required for the destination will be confirmed by the Company
Physician and utilizing the CDC website (www.cdc.gov).
Other situations a Fitness to Work Evaluation may be required
When the employee's First Line Supervisor / Offshore Superintendent or Offshore
Coordinator observes and identifies or otherwise becomes aware of any medical
condition which can be anticipated to further affect the employees ability to safely
perform the essential functions of his or her job (e.g. such as the employee being
subject to unpredictable sudden unconsciousness in a hazardous situation). When
the employees observed and identified physical or mental condition can be
anticipated to subject the employee, co-workers, or the public to a substantial risk of
harm.
Procedure for Fitness to Work Evaluations
1) Human Resources Department is to obtain completed medical questionnaire
from all prospective employees and current employees who meet terms for
Fitness to Work Evaluations.
2) Human Resources Department is to arrange Substance Abuse Screening Test
for all prospective employees in adherence to Moreno Group LLC and
Subsidiaries Drug and Alcohol Policy.
3) Human Resources Department to arrange Medical Examination as part of the
conditional job offer acceptance process and for current employees who meet
terms for Fitness to Work Evaluations.
I9.4
I9.6
The table below outlines the hours of service a DOT Covered Drivers my work/drive:
1. Drivers may drive up to 11 hours in the 14-hour on-duty window after they
come on duty following 10 or more consecutive hours off duty.
2. The 14-hour on-duty window may not be extended with off-duty time for
meal and fuel stops, etc.
3. The prohibition on driving after being on duty 60 hours in 7 consecutive
days, or 70 hours in 8 consecutive days, remains the same, but drivers can
"restart" the 7/8 day period anytime a driver has 34 consecutive hours off
duty.
4. CMV drivers using the sleeper berth provision must take at least 8
consecutive hours in the sleeper berth, plus 2 consecutive hours either in
the sleeper berth, off duty, or any combination of the two.
The table below outlines the hours of service for a passenger carrying vehicles:
Moreno Group LLC and Subsidiaries shall permit or require any driver used to
drive a passenger-carrying commercial motor vehicle, nor shall any such driver
drive a passenger-carrying commercial motor vehicle:
1. More than 10 hours following 8 consecutive hours off duty; or
2. For any period after having been on duty 15 hours following 8 consecutive
hours off duty
Moreno Group LLC and Subsidiaries shall permit or require a driver of a
passenger-carrying commercial motor vehicle to drive, nor shall any driver drive a
passenger-carrying commercial motor vehicle, regardless of the number of motor
carriers using the driver's services, for any period after
1. Having been on duty 60 hours in any 7 consecutive days if the employing
motor carrier does not operate commercial motor vehicles every day of the
week; or
2. Having been on duty 70 hours in any period of 8 consecutive days if the
employing motor carrier operates commercial motor vehicles every day of
the week.
Each individual employee is personally responsible for managing the risks
associated with prolonged working hours and shall discuss any concerns with
their supervisor. The supervisor is responsible for appropriate addressing on
the employees concerns.
Rest Breaks
In an effort to minimize the potential for fatigue, breaks will be provided on a
designated frequency. During the summer months, First Line Supervision will be
responsible for evaluating the need and providing if warranted, additional breaks to
minimize the potential for heat related illnesses and/or fatigue.
I9.7
I9.9
Attachment 1
I9.10
Non DOT
Physical
Shipping /Receiving
Coordinator
Mechanic
Service Technician
Electricians
Electricians Helpers
DOT Driver
Service Manager
Store Manger
Carpenter
Housekeeping
Crane/Cherry picker
Operator
Plumbers Helper
Mechanic Helper
Painter/Blasting
X
X
X
X
X
X
X
X
X
X
DOT
Physical
Respirator
Questionn
aire
Pulmonary
Function
Exam
Respirator
Fit Test
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
X
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
Audio
gram
Serum
Aluminum
Blood Test
Chest
X-Ray
OSHA
Blood
Lead
Level
CBC
Blood
Test
SMAC
Blood
Test
Blood
Level
ZPP
PS
PS
Vision
Exam
Non
DOT
Drug
Test
X
X
X
X
X
X
X
X
X
X
X
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
X
PS
PS
PS
PS
PS
PS
PS
PS
X
X
X
PS
PS
PS
PS
PS
X
X
X
X
X
X
X
I9.10.a.1
DOT
Drug
Test
PS
X
PS
PS
X
PS
Administrative
Personnel
Control Panel
Specialist
DOT Driver
Electricians
Electricians
Helpers
Fitter (Curtis Lane)
Fitter (Fourchon)
Fitter (Harvey)
Fitter (Ingleside)
Fitter (Offshore)
Fitter (Topside)
Foreman
Helper (Curtis
Lane)
Helper (Fourchon)
Helper (Harvey)
Helper (Ingleside)
Helper (Topside)
Instrumentation
Fitter
Instrumentation
Technicians
Management
Metering
Specialist
Offshore Crane
Operator
Offshore Rigger
Offshore
Superintendents
I9.10.a.2
DOT
Physical
Respirator
Questionn
aire
Pulmonary
Function
Exam
Respirator
Fit Test
Audio
gram
Serum
Aluminum
Blood Test
Chest
X-Ray
OSHA
Blood
Lead
Level
CBC
Blood
Test
SMAC
Blood
Test
Blood
Level
ZPP
Vision
Exam
Non
DOT
Drug
Test
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
X
X
X
X
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
X
X
X
X
X
PS, X3
PS, X3
PS, X3
X 1,2
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
X
X
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
X
X
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X3
X3
X3
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS, X3
PS, X3
DOT
Drug
Test
X3
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS, X3
PS
PS
PS,
X3
PS
PS
PS
X3
X3
Power Generating
Technicians
Sales
Van Driver
Welder (Curtis
Lane)
Welder (Fourchon)
Welder (Harvey)
Welder (Ingleside)
Welder (Offshore)
Welder (Topside)
Onshore Crane or
Cherry Picker
Operator
Onshore or
Offshore Painter /
Sand Blaster
Onshore Rigger
Onshore
Supervisors
DOT
Physical
Respirator
Questionn
aire
Pulmonary
Function
Exam
Respirator
Fit Test
PS
PS
PS
Audio
gram
Serum
Aluminum
Blood Test
Chest
X-Ray
OSHA
Blood
Lead
Level
CBC
Blood
Test
SMAC
Blood
Test
PS
Blood
Level
ZPP
Vision
Exam
PS
X
X
PS
PS
PS
X
X
X
X
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
X
Non
DOT
Drug
Test
DOT
Drug
Test
PS
X
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
X
X
X
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X1,2
PS
PS
PS
PS
PS
PS
Sub #1 Curtis Lane - All employees, Harvey All employees, Sub #2 Topside East and West - All employees, Sub #3 Environmental
Topside = East, West and Lake Charles Topside Facilities
I9.10.a.3
DOT
Physical
Respirator
Questionn
aire
Pulmonary
Function
Exam
Respirator
Fit Test *
Audio
gram
Serum
Aluminum
Blood Test
Chest
X-Ray
OSHA
Blood
Lead
Level
CBC
Blood
Test
SMAC
Blood
Test
Blood
Level
ZPP
Non
DOT
Drug
Test
Vision
Exam
X
X
X
Administrative
Sales
Clerical
Carpenter
Plumber
Insulator
DOT
Drug
Test
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
PS
PS
PS
X
X
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
X
X
X
X
X
*All employees who may be required to wear respirators must be initially, and annually fit-tested with the specific respirator(s) that
they may be required to wear. (Pulmonary function tests will be performed in conjunction with all fit-tests)
DOT
Physical
Respiratory
Question
PFT
Fit
Test
**
Audio.
Serum
AL Blood
Test
Chest
X-Ray
Blood
Lead
CBC
SMAC
ZPP
Vision
Drug
Screen
Administrative
Sales
Clerical
Cleaning Techs,
including
Foremen
X
X
PS
PS
PS
DOT
Drug
Test
**All employees who may be required to wear respirators must be initially, and annually fit-tested with the specific respirator(s) that
they may be required to wear. (Pulmonary function tests will be performed in conjunction with all fit-tests)
Dii LLC (Emergency Response, Government Projects, etal) Fitness to Work Evaluations*
Administrative, Sales, and Clerical personnel have the same Fitness to Work requirements as Construction and
Environmental Divisions for their positions. All other employees are subcontractors. These subcontractors will have all of the
appropriate fitness evaluations according to project requirements as designated by S/H & E Dept.
I9.10.a.4
Administrative
Administrative/
McKee
Helper/ other
Helper/ McKee
Carpenter/ other
Carpenter/ McKee
Iron Worker/ other
Iron Worker/ McKee
Operator (crane)/
other
Operator (crane)/
McKee
Electrician/ other
Electrician/ McKee
Instrument Fitter/
other
Instrument Fitter/
Mckee
Millright/ other
Millright/ McKee
Instrument Tech./
other
Instrument Tech/
McKee
Pipefitter/ other
Pipefitter/ McKee
Boilermaker/ other
Boilermaker/ McKee
Welder, Multi Process
Alloy/ other
Welder, Multi Process
Alloy/ McKee
DOT
Physical
Respirator
Questionn
aire
Pulmonary
Function
Exam
Respirator
Fit Test
Audio
gram
Serum
Benzene
Blood
Test
Chest
X-Ray
OSHA
Blood
Lead
Level
CBC
Blood
Test
SMAC
Blood
Test
Blood
Level
ZPP
Vision
Exam
Non
DOT
Drug
Test
DOT
Drug
Test
X
X
PS
X
PS
X
PS
X
PS
X
PS
X
X
X
PS
X
PS
X
X
X
PS
X
PS
X
X
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
X
X
X
X
X
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
X
X
X
X
X
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
X
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
X
X
X
X
X
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
X
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
PS
X
X
X
X
X
X
X
X
X
X
X
X
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
X
X
X
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
I9.10.a.5
PS
X
X
X
X
Pulmonary
Function
Exam
Respirator
Fit Test
PS
X
X
Non DOT
Physical
Audio
gram
Serum
Benzene
Blood
Test
Respirator
Questionn
aire
DOT
Physical
Chest
X-Ray
OSHA
Blood
Lead
Level
CBC
Blood
Test
SMAC
Blood
Test
Blood
Level
ZPP
Vision
Exam
Non
DOT
Drug
Test
PS
PS
PS
PS
PS
PS
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
Welder/ other
PS
Welder/ McKee
Welder, Rig/ other
Welder, Rig/ McKee
Mechanical Leadman/
other
Mechanical Leadman/
McKee
Foreman 1/ Other
X
PS
X
PS
PS
PS
PS
PS
PS
PS
PS
X
X
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
PS
X
X
X
X
X
X
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
X
PS
X
X
X
X
X
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
PS
X
X
Foreman 1/ McKee
General Foreman/
other
General Foreman/
McKee
Timekeeper/ other
Timekeeper/ McKee
Safety Supervisor/
other
Safety Supervisor/
McKee
Quality Control/ other
Quality Control/
McKee
I9.10.a.6
DOT
Drug
Test
Pulmonary
Function
Exam
Respirator
Fit Test
Audio
gram
Serum
Benzene
Blood Test
Chest
X-Ray
OSHA
Blood
Lead
Level
CBC
Blood
Test
SMAC
Blood
Test
Blood
Level
ZPP
Vision
Exam
Non
DOT
Drug
Test
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
Non
DOT
Physical
Planner/ Scheduler/
other
Planner/ Scheduler/
McKee
Project Control/
other
Project Control/
McKee
Superintendent/
other
Superintendent/
McKee
Area
Superintendent/
other
Area
Superintendent/
McKee
General
Superintendent/
other
General
Superintendent/
McKee
Project Manager/
other
Project Manager/
McKee
DOT
Physical
DOT
Drug
Test
I9.10.a.7
Non DOT
Physical
Administrative
Personnel
SH&E Field
Personnel
PS = Project Specific
I9.10.a.8
DOT
Physical
Respirator
Questionn
aire
Pulmonary
Function
Exam
Respirator
Fit Test
Audio
gram
Serum
Aluminum
Blood Test
Chest
X-Ray
OSHA
Blood
Lead
Level
CBC
Blood
Test
SMAC
Blood
Test
Blood
Level
ZPP
Vision
Exam
Non
DOT
Drug
Test
DOT
Drug
Test
X
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
PS
Non DOT
Physical
DOT
Physical
Respirator
Questionn
aire
Pulmonary
Function
Exam
Respirator
Fit Test
Audio
gram
Serum
Aluminum
Blood Test
Chest
X-Ray
OSHA
Blood
Lead
Level
CBC
Blood
Test
SMAC
Blood
Test
Blood
Level
ZPP
Vision
Exam
Non
DOT
Drug
Test
Driver
Warehouse Puller
Steel Supply
Puller
Warehouse
Manager
Receiving/Shippin
g Manager
DOT Driver
Processing
employee
X
X
X
X
DOT
Drug
Test
X
X
I9.10.a.9
Attachment 2
I9.11
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
10
Yes
No
11
Yes
No
12
Went to a dentist?
Yes
No
13
Yes
No
If you answered Yes to any questions above (1-13), you must complete and submit
the Medication Questionnaire on the back of this document directly to your
supervisor.
I certify that the above answers are true and correct.
I further certify that I am fully fit to return for my regular hitch and I am physically and
mentally able to safely perform my job.
___________________________________
DATE
________________________________
EMPLOYEE SIGNATURE
________________________________
PRINT EMPLOYEES NAME
I9.11.a.1
Medication Questionnaire
As described in Moreno Group LLC and Subsidiaries
Substance Abuse and
Contraband Policy, prescription and non-prescription medications may interfere with
safe and effective performance of duties or operation of equipment. In order to
maintain a safe workplace, Moreno Group LLC and Subsidiaries would like to ensure
any medication you are taking will not hinder your ability to work safely or perform the
essential function of your job. Therefore, in addition to testing completed as part of
Moreno Group LLC and Subsidiaries anti-drug testing and alcohol misuse prevention
plans, Moreno Group LLC and Subsidiaries periodically inquires about employee use
of prescription and non-prescription medications which can reasonably be anticipated
to affect the employees ability to perform the essential functions of his or her job.
Are you now taking any prescription or non-prescription
medications which you believe may affect your ability to
make decisions, remain alert, reactive, and responsive on
the job, or pose a threat to your safety or that of others
such that you believe the use of such medication can
reasonably be anticipated to affect your ability to perform
the essential functions of your job?
Circle one: Yes or No
IF YOU ANSWERED YES, YOU ARE NOT TO BEGIN WORKING WITHOUT YOUR
SUPERVISORS APPROVAL, AND MUST COMPLETE THE CHART BELOW.
Dosage of
Medication
I9.11.a.2
Date
Employees Signature
Hazard Communication
Program
Page: 1 of 7
Original: 07/01/1998
Revised: 01/01/2008
its
I10.2
I10.4
I10.5
Attachment 1
I10.6
Chemical Name:
Chemical Manufacturer:
Type of Storage:
Is Storage Pressurized:
Yes_______
No______
Date:
Approved By:
Date:
Recommendation(s):________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
I10.6.a.1
Attachment 2
I10.7
I10.7.a.1
Hearing Conservation
Page: 1 of 5
Original: 01/01/2001
Revised: 10/01/2006
Hearing Conservation
Purpose
The purposes of this program it to set forth the procedures, which have been
established to evaluate and control employee exposure to excessive workplace
noise. It is intended to address the requirements of OSHA 1910.95, Occupational
Noise Exposure.
Scope
The scope of this plan requires Moreno Group LLC and Subsidiaries to administer a
hearing conservation program whenever employee noise exposures equal or exceed
an 8-hour time-weighted average (TWA) sound level of 85 decibels (dB) measured
on the A-weighted scale (slow response) or, equivalently, a dose of fifty percent.
Responsibilities
The Facility / Site Manager / Offshore Manager or Designee is responsible for:
Assuring that noise level surveys are conducted for all typical operations /
equipment.
Notify SH&E Department when changes in the work area may affect the noise
levels.
Posting and maintaining warning signs where hearing protection is required.
Conferring with the supervisors to identify noise hazards and hearing
protection required for a specific job / task.
Audit compliance with the use of proper hearing protection.
Implement and manage this program for covered positions.
Maintaining records of employee audiometric test results per Access to
Medical records requirements.
The First Line Supervisor or Offshore Superintendent is responsible for:
Understanding and implementing
Conservation program.
the
requirements
of
the
Hearing
I11.1
Administrative Controls
Administrative controls shall be exercised to reduce noise levels, when practical.
Monitoring
Covered Employees
Employees whose noise exposures equal or exceed 85 dBA for an 8-hour TWA on
the A scale (slow response) or 82.5 dBA for a 12-hour TWA on the A scale (slow
response) are included in the Hearing Conservation Program. Any exception to this
criterion will be made on an individual case basis.
All personnel are included in the Hearing Conservation Program, with the exception
to office personnel and those employees not exposed to 85 dBA for an 8-hour TWA.
Personal Sampling
Personal noise monitoring is to be conducted to determine the noise exposures of
employees who are included in the Hearing Conservation Program.
Results of noise monitoring will be filed in the employees medical record file. A
notification letter shall be distributed to the employee explaining the results to them,
on their personal noise monitoring.
Method of Noise Measurement
Employee exposure measurements are obtained by the use of noise dosimeters and
sound level meters.
Noise dosimeters measure all continuous, intermittent, and impulsive sound levels
from 80 dB to 130 dB, which are integrated into TWAs.
Measurements are obtained on the A-weighted scale using the slow response
mode.
Equipment used to monitor employee noise exposures shall be calibrated before
and after each days use in accordance with the equipment calibration instructions.
Observation
All employees and/or their representatives are entitled to observe any noise
monitoring that is to be conducted.
Audiometric Testing and Evaluation
Audiometric or Hearing Testing
Testing is available on an annual basis to all Moreno Group LLC and Subsidiaries
employees covered by this program.
I11.3
The audiometric test will be compared to the baseline test to determine if a Standard
Threshold Shift (STS) has occurred.
A certified audiologist or technician will perform these tests.
All participating employees will receive written individual test results from the testing
company.
Employees are to be advised to avoid high noise levels, occupational and nonoccupational, for fourteen (14) hours prior to taking an audiogram.
Baseline Audiogram
Moreno Group LLC and Subsidiaries shall offer a baseline audiogram within six (6)
months of employment, or during a pre-placement physical.
Audiogram Evaluation
The testing facility will evaluate all audiogram to determine if an STS has occurred.
The STS is defined as a change in hearing threshold relative to the baseline
audiogram of an average of 10 dB or more at 2000, 3000, and 4000 Hz in either ear.
Occupational age-adjusted noise-induced threshold shifts greater than or equal to an
average of 25 dB at 2000, 3000 and 4000 Hz in either ear shall be recorded as an
occupational illness on the OSHA 300 log. A follow-up audiogram will be performed
to confirm this result.
Employees included in the Moreno Group LLC and Subsidiaries Hearing
Conservation Program who experience an STS will be notified in writing.
A follow-up audiogram within thirty (30) days of the original audiogram.
Follow-up Procedures
All employees will be notified of an STS in writing within 21 days.
The following actions are to be taken (unless a physician determines that the STS is
not work related):
Refer as necessary for clinical evaluations or additional testing.
Inform employees with non-work related ear problems of need for
examination.
Provide employees with hearing protectors (if not already wearing) train in
care and use and require them to be worn.
I11.4
Hearing Protection
Evaluation
Hearing protection provide will be evaluated to ensure the appropriate Noise
Reduction Rating (NRR) is provided.
Availability
Hearing protectors are available through the customer and the Operations Manager.
Requirements
Hearing protectors are required to be worn when the following exist:
Employees are exposed to 85 dBA TWA or greater, as identified by posting of
signs in designated areas.
During tasks that generate noise.
Precautions
Posting of signs stating Caution Hearing Protection is Required in This Area or
Hearing Protection is Required Beyond This Point have been posted in areas with
noise levels of 85 dBA or greater, measured with a sound level meter.
All employees working in the posted areas shall wear approved hearing protectors.
Supervisors are responsible for ensuring that employees adhere to the hearing
protection requirements.
I11.5
Page 1 of 5
Original: 05/12/2009
Revised:
I12.1
Requirements
Water Container Cleaning Instructions
Dynamic Industries, Inc. will ensure water containers are cleaned utilizing the below
procedure each time before a water container is utilized:
Wash hands with anti-bacterial soap or hand sanitizer and utilize nitrile
gloves prior to cleaning and / or filling water containers.
Before opening the water container, remove the tape around the outside of
the lid and thoroughly clean the outside of the container, lid, handle and
spout area. Utilize a plastic bristle brush marked For Outside Use Only.
Clean and disinfect inside and water container and spout utilizing a 1:50
bleach to water disinfectant. For spray bottles utilize 24oz. water and 3 tsp.
bleach.
For containers that have not been used in over 3 days, new containers or
containers with excessive dirt/grime, the following needs to be performed:
o Thoroughly wash container using soap and water.
o Use a long handled bristle brush marked For Inside Use Only, and
scrub the inside of the container.
o Follow below disinfecting procedure.
I12.2
For containers that are used daily and are not excessively soiled, only the
below disinfecting procedure shall be utilized:
o Spray or wipe the inside of the container and lid using the 1:50 bleach
to water disinfectant.
o Be careful to drench all components of the container including the lid
and spout area.
o Allow the disinfecting solution to sit in the container for 3 minutes prior
to discarding it.
o Do not rinse the container after disinfecting as this can introduce new
contaminates.
o The container is ready for use. It can be immediately filled after
decontamination or the top can be secured and container can be filled
later. If container is to be filled later, repeat the bleach solution
disinfecting steps prior to filling the containers with water.
Filling Water Container Instructions:
o Wash hands with anti-bacterial soap or hand sanitizer and utilize
nitrile gloves.
o Fill container with ice then top off with water.
o If ice machine is used, ensure ice scoop is used.
o Do not handle ice or water with bare hands, ensure nitrile gloves are
utilized.
o All hoses used for cleaning and filling of water coolers should only be
used for this purpose.
o After the container is filled, secure the lid, dry off the container and
place tape around the lid.
o Write the time and date the container was filled on the tape.
Electrolyte Supplements
Electrolyte supplements in addition to water will be provided to employees when
deemed necessary by Dynamic Industries Inc.s Facility Management and Safety,
Health and Environmental Department during extreme heat conditions.
During extreme heat conditions, employees will be provided two (2) individual
packets of Sqwencher or equivalent electrolyte replacement supplements to be
consumed at morning and afternoon break. This will be distributed to each
employee by their respective foremen each morning at the SH&E Meeting. When
utilizing electrolyte supplements, ensure water is still consumed in adequate
quantities.
I12.3
Attachment 1
I12.4
Attachment 2
I12.5
Q: How many workers in United States are affected by heat stress every year?
A: 10 million or about 7% of the US workforce
Q: Other than the health effects of the individual, what other problems does heat stress cause?
A: Decrease in productivity,
A: Decrease in alertness,
A: Decrease in morale,
A: Increase in proneness to accidents
Q: What is the prime cause of heat stress?
A: Dehydration
HEAT EXHAUSTION
Symptoms
1. Heavy sweating
2. Intense thirst from dehydration
3. Fatigue, weakness or loss of
coordination
4. Tingling in hands and feet or
headache
HEAT STROKE
Early Symptoms
1. High body temperature
2. Hot, red or flushed, dry skin
3. Headache or dizziness
4. Confusion or delirium
Advanced Symptoms
1. Seizure or convulsions
2. Loss of consciousness
3. No detectable pulse
I12.5.a.1
Treatment
1. Lower the victims body temperature as fast as possible
2. Dont give liquids to unconscious victims
Other tips for controlling heat stress
Individuals:
Allow your body to become acclimated to your surroundings
Follow scheduled work/rest cycles to avoid overexertion
Drink before youre thirsty
Drink 6-8 ounces of cool water every 15 minutes
1 hour of strenuous activity requires 1 liter of fluid replacement
Avoid alcohol, coffee, tea or soda
Consume a light, cool lunch instead of hot, heavy meals
Leadership:
Ensure everyone is trained on the symptoms of heat stress
Give consideration to inclusion of heat stress as a hazard when developing JSAs and ensure
mitigation steps are followed
Heat Index
I12.5.a.2
117
100
80
60
40
74
62
44
47
41
18
d
W
in
rm
St
o
Co
ld
te
r
W
in
He
at
ne
ca
Hu
rri
rn
a
nin
ht
To
do
20
0
Lig
140
120
Fl
oo
AM I HYDRATED?
10 Year Average
180
160
We lose about 8-10 cups (64-80 oz) of water per day (WITHOUT exercise) through
breathing, perspiration and normal bodily functions.
75% of people are dehydrated.
As little as 2% loss in water content begins to cause the brain to lose alertness and the body
to feel fatigue. In 37% of us, the thirst mechanism is so weak it is often mistaken for hunger.
The number one trigger of day time fatigue and poor performance is not lack of sleep or
stress but dehydration.
Formula
Body Weight + 12 = Daily Requirement (ounces)
2
Example
150 lb person = (150/2)+12 = 75+12 = 87 oz.
I12.5.a.3
Hexavalent Chromium
Program
Page: 1 of 19
Original: 08/29/2006
Revised:
I13.1
TYPES
OF
HEXAVALENT
CHROMIUM CHEMICALS
It is important to note that welding filler metals typically have material properties that
closely mirror the base metal compositions. It has been established that the higher
the chromium level in the supplied materials, the more Cr(VI) will be generated in
welding fumes. Studies performed by the Navy Research Center determined that
approximately 90 percent of the fumes generated during welding come from the filler
metal, and the other 10 percent comes from the base metal.
Stainless steel electrodes and filler wires contain metallic chromium and chromium
alloys. Stainless steel filler metals contain little or no chromium oxide, but the high
heat from the welding arc causes the metallic chromium to oxidize and transmits it
into the air as a fume. The high-heat oxidation process caused by the arc produces
Cr(VI) as a byproduct in the fume, which becomes airborne part of the welding
environment.
The type of welding or cutting also influences the generation of metal fumes and
therefore the concentration of Cr(VI). The highest fume exposures--from highest to
lowest--are from arc gouging and plasma arc cutting, then shielded metal arc
I13.4
welding (stick welding), then gas metal arc (MIG)/gas tungsten arc (TIG) welding.
However, when considering Cr(VI) fume levels apart from other metal fumes, the
lowest Cr(VI) exposures are often seen in welding processes that use a flux instead
of a shielding gas.
The next most significant source of Cr(VI) exposure within Moreno Group LLC and
Subsidiaries operations is the generation of dust, fumes or mist from the following
operations:
Abrasive blasting involving grit contaminated with Cr(VI);
Abrasive blasting on base material coated with any chromate or dichromate
paint;
Grinding, drilling, or other similar aggressive activity on any chromate or
dichromate paint;
Welding or torch cutting on any chromate or dichromate paint;
Painting activities that use chromate or dichromate paint; and
Mist or dust generated from using chromium-containing chemicals (e.g.
corrosion inhibitors).
HEALTH EFFECTS
The primary routes of exposure to Cr(VI) are inhalation and skin contact. Cr(VI) is a
carcinogen and is known to cause lung cancer. It is also suspected of causing
leukemia and Hodgkins Disease. Other acute and chronic health effects cited by
OSHA that are associated with Cr(VI) include:
Reproductive disorders;
Stomach, kidney, and bladder diseases;
Asthma;
Nasal septum ulcerations and perforations;
Skin ulceration (chrome holes); and
Allergic and irritant contact dermatitis.
Cr(VI) will irritate the nose, throat, and lungs and repeated or prolonged exposure
can damage the mucous membranes of the nasal passages and result in ulcers. In
severe cases, exposure causes perforation of the nasal septum (the wall separating
the nasal passages).
I13.5
Prolonged skin contact with Cr(VI) can result in dermatitis and skin ulcers. Some
individuals may develop an allergic sensitization to chromium and direct eye contact
with chromic acid or chromate dusts can cause permanent eye damage.
CONTROLLING EXPOSURES AND MANAGING RISKS
EXPOSURE LIMITS
The OSHA standard regulates the permissible exposure limit (PEL) for Cr(VI) to 5
micrograms per cubic meter (g/ m3) of air as an 8-hour time-weighted average
(TWA). Respiratory protection, safe work practices, and engineering controls are
required above 5 g/ m3 TWA and above.
When feasible, use engineering and work practice controls to reduce and maintain
workforce exposure to chromium (VI) at or below the 5 g/ m 3. Wherever feasible
engineering and work practice controls are not sufficient to reduce workforce
exposure to or below the PEL, reduce workforce exposure to the lowest levels
achievable, and supplement them using respiratory protection.
The OSHA standard also sets an action level (AL) of 2.5 g/ m 3 as an 8-hour TWA
exposure. This AL mandates medical assessments if an employee is exposed for 30
days or more in a year (regardless of location). This level also triggers the need to
maintain medical assessment records, provide training, and conduct additional
exposure assessments.
DETECTING AND MEASURING CR(VI) IN THE WORKPLACE
OSHA requires that each employer determine the 8-hour TWA exposure for each
employee exposed to Cr(VI) within their workplace or work operation. Moreno
Group LLC and Subsidiaries will utilize air monitoring to determine the TWA
exposure on Cr(VI) projects.
RISK ASSESSMENT
Each operating facility must conduct an assessment to ascertain if any chromiumcontaining products or materials are being utilized. In addition, facilities should
conduct such an assessment for each maintenance project at the planning stage.
Initial assessments may include a review of Material Safety Data Sheets,
engineering specifications, product labels and manufacturers product information
sheets. If chromium-containing materials are determined to exist (e.g. stainless
steel, chrome steel, carbon steel, chromium containing paints or corrosion inhibitors)
or be periodically used (e.g. chromium containing welding rods or paints) in the
workplace, then additional information shall be gathered to identify:
The types and amounts of materials;
How many people are involved; and
The specific work activities involving chromium.
I13.6
QUANTIFIED SAMPLING
A comprehensive sampling and data collection program is needed to quantify the
risk of Cr(VI) exposure to personnel. Moreno Group LLC and Subsidiaries shall
perform initial monitoring to determine the 8-hour TWA exposure for each employee
on the basis of a sufficient number of personal breathing zone air samples to
accurately characterize full shift exposure on each shift, for each job classification, in
each work area. Representative sampling may be conducted instead of sampling all
employees in order to meet this requirement, as long as the employees sampled are
those expected to have the highest Cr(VI) exposures.
All sampling must be conducted according the analytical specifications of the OSHA
standard (OSHA standard ID 215) and be tested by a laboratory with accreditation
from the American Industrial Hygiene Association (AIHA), the National Voluntary
Laboratory Accreditation Program (NVLAP), and the National Institute of Standards
and Technology (NIST).
Personal exposure monitoring will be conducted by an industrial hygienist or a
specifically trained technician (e.g. occupational health technician) under the
direction of an industrial hygienist using integrated sampling methods. Monitoring
will be conducted as an initial assessment for all tasks identified as having a
potential for Cr(VI) exposure, periodically in accordance with the OSHA standard
when levels are determined to exist above the action level or when
workers/management express any reasonable exposure concern.
An industrial hygienist will report laboratory analytical results to the supervisors,
SH&E coordinators and workers involved in the monitored task.
If initial monitoring indicates that employee exposures are below the action
level, monitoring may be discontinued for those employees whose exposures
are represented by such monitoring.
If monitoring reveals employee exposures to be at or above the action level,
periodic monitoring must be performed for those employees at least every six
months.
If monitoring reveals employee exposures to be above the PEL, periodic
monitoring must be performed for those employees at least every three
months.
If periodic monitoring indicates that employee exposures are below the action
level, and the result is confirmed by the result of another monitoring taken at
least seven days later, monitoring for those employees whose exposures are
represented by such monitoring may be discontinued.
Additional monitoring must be performed when there has been any change in
the production process, raw materials, equipment, personnel, work practices,
or control methods that may result in new or additional exposures to Cr(VI), or
when there is any reason to believe that new or additional exposures have
occurred.
I13.7
effective method but may not be the most practical, particularly based upon location
of the task being performed or for blasting/painting operations. Local Exhaust can
be provided by a partial enclosure of the source such as a ventilated work bench, or
by smoke suckers positioned as close to the point of welding as possible. Hoods and
ductwork should be constructed of fire-resistant materials.
Some examples of local exhaust ventilation are portable smoke eaters and fume
extraction welding guns. Local exhaust is best when you have:
Limited mobility;
Limited openings;
Interior obstructions;
Few sources (e.g. welders); and
More toxic alloys.
Some examples of dilution ventilation are centrifugal fans, axial fans and
venturi eductors. Dilution ventilation is best when you have:
Mobile work;
Multiple openings;
Few obstructions;
Many sources; and
Less toxic alloys.
ADMINISTRATIVE CONTROLS
Facilities/sites must establish a regulated area wherever an employee's exposure to
airborne concentrations of Cr(VI) is, or can reasonably be expected to be, in excess
of the PEL. Regulated areas must:
Be demarcated from the rest of the workplace in a manner that adequately
establishes and alerts employees of the boundaries of the regulated area;
and
Limit access to regulated areas to personnel authorized and required by work
duties to be present in the regulated area.
Administrative controls include written instructions (e.g. written contract
specifications, JSEAs) and also include posted regulated areas and safe work
practices. If possible, always use work techniques that generate the least amount of
welding fume or other airborne chromium-containing materials.
I13.9
I13.11
I13.12
RECORDKEEPING
Monitoring records must include the specific information outlined in OSHAs new
Cr(VI) standard as follows:
The date of measurement for each sample taken;
The operation involving exposure to Cr(VI) that is being monitored;
Type of ventilation used
Sampling and analytical methods used and evidence of their accuracy;
Number, duration, and the results of samples taken;
Type of personal protective equipment, such as respirators worn; and
Name, social security number (or unique personal ID number), and job
classification of all employees represented by the monitoring, indicating which
employees were actually monitored.
Medical surveillance records must include the specific information outlined in
OSHAs new Cr(VI) standard as follows:
Name and social security number;
A copy of the PLHCP's written opinions;
A copy of the information provided to the PLHCP as required by paragraph
(k)(4) of 29 CFR 1910.1026 Chromium (VI).
In accordance with 29 CFR 1910.1020 Access to Employee Exposure and Medical
Records, employee exposure records must be maintained for at least 30 years and
medical surveillance records, if applicable, must be maintained for the duration of
employment plus 30 years. In addition, records must be made available to
employees.
ACTION LEVEL LIMIT
The Action Level for airborne chromium is 2.5 micrograms per cubic meter of air (2.5
g/m3) calculated as an 8-hour time-weighted average (TWA).
Whenever workers airborne total chromium exposures exceed due to monitoring,
the Action Level, the following will be implemented for the work project:
Periodic monitoring at least every six months.
I13.13
HEALTH EFFECTS
The primary routes of exposure to hexavalent chromium are inhalation and skin
contact. Hexavalent chromium is a carcinogen and is know to cause lung cancer. It
is also suspected of causing leukemia and Hodgkins disease. Other acute and
chronic health effects cited by OSHA that are associated with hexavalent chromium
include:
Reproductive disorders
Stomach, kidney and bladder diseases
Asthma
Nasal septum ulcerations and perforations
Skin ulceration (chrome holes) and
Allergic and irritant dermatitis
Hexavalent chromium will irritate the nose, throat and lungs and repeated or
prolonged exposure can damage the mucous membranes of the nasal passages
and result in ulcers. In severe cases, exposure causes perforation of the nasal
septum (the wall separating the nasal passages).
Prolonged skin contact with hexavalent chromium can result in dermatitis and skin
ulcers. Some individuals may develop an allergic sensitization to chromium and
direct eye contact with chromic acid or chromate dusts can cause permanent eye
damage.
COMPETENT PERSON
All work activities where employee airborne chromium exposures may exceed the
PEL will include a competent person in both the planning and performing stages of
projects involving chromium exposure.
The competent person will be a person with training and experience in conduction
jobs involving airborne chromium exposure. The competent person will have the
capability of identifying hazards and the authority to take immediate action to
eliminate them.
The competent person will be at the work site at all times while airborne chromium
exposure activities are in progress. They may have other job duties, but must be
able to monitor work continuously for hazards or deficiencies, and the authority to
take immediate corrective action.
EMPLOYEE INFORMATION AND TRAINING
All employees who work on projects where airborne chromium and exposures are
known to or expected to be at or above the PEL will be provided information and
I13.15
training on the hazards of airborne chromium and measures for controlling these
hazards and protecting health.
Employees will receive initial comprehensive airborne chromium training before
performing work that may involve airborne chromium exposure. This training will be
repeated annually as a refresher course.
The content of airborne chromium training will include:
The specific nature of activities or operations that may result in airborne
chromium exposure above the Action Level
The health effects and risks of airborne chromium exposure
OSHA standards and guidelines for airborne chromium exposure
Engineering controls, including containments and ventilation systems
Work practices for controlling airborne chromium and exposure, including
information, warning signs, housekeeping, protective clothing and proper
hygiene facilities and practices
Respiratory protection for controlling airborne chromium exposure, including
fit testing
Methods for monitoring airborne chromium concentrations and exposures
The medical surveillance program including medical removal
When conducting airborne chromium exposure activities on a multi-employer work
site, Moreno Group LLC and Subsidiaries will notify other employers of the nature of
the chromium exposure system in effect, and the potential need to take measures to
protect their employees. Notification to other employers will contain the following:
NOTICE - MORENO GROUP LLC AND SUBSIDIARIES IS PERFORMING
ACTIVITIES AT THIS JOB SITE THAT MAY CREATE AIRBORNE CHROMIUM
EXPOSURE. ALL CONTRACTORS AT THIS JOB SITE SHALL REMAIN CLEAR
OF ANY CHROMIUM EXPOSURE AREA.
ACCESS INTO CHROMIUM
EXPOSURE AREA IS CONTROLLED BY THE MORENO GROUP LLC AND
SUBSIDIARIES JOB FOREMAN. ONLY TRAINED, QUALIFIED WORKERS ARE
PERMITTED TO ENTER CHROMIUM EXPOSURE AREAS AND MUST WEAR
RESPIRATORS AND/OR PROTECTIVE CLOTHING.
WELDING OPERATIONS
Welders at Moreno Group LLC and Subsidiaries are exposed to hexavalent
chromium-CR(VI) through the following means:
Stainless steels or other chromium-containing alloys represent the source of
hexavalent chromium in welding operations.
I13.16
Most welding operations join metals by heating the base and/or filler metal to
temperatures at or above the melting point and vaporization temperature of
the weld joint material.
A portion of the metal vapor, including chromium vapor originating from the
base metal, consumable electrode, surface coating, or surface contaminants
instantaneously reacts with atmospheric oxygen and condenses into solid
particles (known as fume) to form metal oxides, such as iron oxide, and
chromium oxides.
o Metallic chromium when vaporized may react with oxygen to form both
trivalent chromium and hexavalent chromium oxide-containing fume.
Hotwork done on galvanized material, such as cutting on grating or handrails
that have been coated with galvanize.
WARNING SIGNS
Warning signs will be posted in the work area around activities where airborne
chromium exposures may exceed the PEL. The work area can be demarcated by
ropes, tape, walls, or containments.
Signs will be posted at every accessible side of the work area. These signs will be
easily visible from a distance so that employee can read the sign and take
necessary protective measures before entering the work area. Signs will read as
follows: WARNING, CHROMIUM WORK AREA.
The competent person will control access of persons into work area.
All persons entering work areas will wear protective clothing and respirators.
Eating, drinking, smoking, and chewing are prohibited in work areas and any area
where airborne chromium exposure may exceed the PEL.
CONTAINMENTS
Where required by federal, state, or local regulation, the project sponsor, or the
project owner, containments will be constructed and used as specified.
The purpose of containments is to restrict or prevent the spread of airborne
chromium or debris to surrounding areas or the environment. While the proper use
of containments can help protect the public and the environment, they generally
cause a significant increase in airborne chromium concentrations in the work area.
Containments may increase the potential for higher employee chromium exposures.
Therefore, the use of well designed exhaust ventilation and the use of more
protective respirators may be necessary to properly protect workers.
I13.17
All exposed employees will be notified in writing of the monitoring results within five
(5) days after receiving these results.
Initial exposure monitoring may not be required when previously collected data has
conclusively determined that current job condition exposure levels will be less than
the PEL.
HOUSEKEEPING
Accumulations of chromium and chromium-containing dust and debris generated by
work activities will be removed and cleaned daily.
All persons doing the clean-up will be trained in performing chromium activities,
respirator qualified, and participate in the medical surveillance program. Respirators
and protective clothing will be worn by all persons doing the cleanup unless
exposure monitoring proves otherwise.
Wherever feasible, HEPA-filtered vacuum cleaners will be used for housekeeping.
All chromium and chromium-containing dust and debris will be collected into sealed
containers. The waste will be tested to determine whether it will be disposed as
hazardous or non-hazardous waste.
RECORDKEEPING
All records relating to training, medical examinations, blood chromium monitoring,
exposure monitoring, and project specific requirements will be maintained by
Moreno Group LLC and Subsidiaries, for the employees length of employment plus
30 years.
OTHER RELEVANT INFORMATION
The compliance program will be kept available at the work site for examination by an
affected employee or authorized person/agency.
The compliance program will be revised and updated at least annually.
I13.19
Page: 1 of 8
Original: 10/01/06
Revised:
Responsibilities
The Facility Manager/Offshore Manager/Yard Foreman or Designee
responsible for:
is
I14.1
H2S
training
and
respiratory
training
and
fit
testing.
portable/gas
test
meter),
and
personal
electronic
Direct-read" digital meter for determining actual concentration with alarm set
points; or
"Alarm only" type (no indication of concentration). This type should only be
used for personnel warning and should not be used as a screening device
because there is no indication of concentration.
Both fixed and personal H2S detection instruments should have a distinctive
audible and visual alarm signal consistent throughout the facility/location
Color-metric indicating tubes These are generally less susceptible to
interferences (such as from other sulfur compounds and hydrocarbons) and
can read higher ranges than most electronic instrumentation. If electronic
instrumentation indicates the presence of H2S where none is suspect, colormetric tubes can be used as a confirmatory source. See the Standard Toxic
Gas Testing for additional information on this equipment.
Lead-acetate paper (commonly a go/no-go type of indicator): generally has
been replaced by other instrumentation. Not recommended, particularly for
personal monitoring.
Calibration - All instrumentation should be calibrated according to the manufacturer's
instructions at least monthly, at the time of servicing or repair, and at the time
of battery replacement. See the Standard, Calibration of Portable Toxic
Gas/Oxygen Meters. A calibration log and maintenance record should be
maintained.
Recommended alarm points for H2S instrumentation are 10 ppm for the low alarm
point and 20 ppm for the high alarm.*
I14.4
Employee(s) must be instructed to evacuate the area immediately, even if the low
alarm is the only one to sound.
Ambient H2S levels should be made in the employee's breathing zone; except that
For tank gauging/sampling purposes, the H2S concentration should be measured at
the level of the thief or gauging hatch, not the breathing zone of the employee. (see
9.c)
Safe Work Practices
Written H2S procedures should identify jobs and work conditions where H 2S may be
of concern and describe appropriate work practices. These procedures should
include at least the following as applicable.
Respiratory protection:
Shall be worn until the concentration of H2S has been established.
Shall be worn for any known or expected environment that equals/exceeds 10
ppm in the employee's breathing zone.
Buddy system and requirements of the standby person:
A standby with respiratory protection is required whenever the H 2S
concentration in the breathing zone could exceed 300 ppm (See 9.c
regarding open hatch tank gauging).
Trained in CPR/First-Aid and appropriate rescue techniques or how to initiate
a rescue response.
Trained on and proficient in the use of SCBA.
Have a two-way radio to request back up assistance if an emergency
develops.
Standby shall be located upwind with a clear view of his/her "buddy."
Ground level is preferable; if the standby must climb to keep his/her "buddy"
in view; the standby should don the SCBA, except the facepiece. If the
standby must actually use the RPE because of potential exposure another
standby located in a "safe" area would be required.
Requirements for gauging/sampling tank which contain a product producing
hydrogen sulfide (H2S) in the tank vapor space are as follows:
For H2S concentration < 10 ppm above the gauging hatch and < 300 ppm
at the gauging hatch, no respiratory protection is required; a standby person
is not necessary (Figure 1).
I14.5
For H2S concentration > 10 ppm above the gauging hatch and < 300 ppm
at the gauging hatch, SCBA or supplied air is required; a standby person is
not necessary (Figure 2).
For H2S concentration > 300 ppm at the gauging hatch, SCBA or supplied
air with escape bottle and a standby person is required (Figure 3).
For the purpose of this discussion, at the hatch means on a plane level with
the top of the hatch.
Alarm investigation
All alarms should be investigated as an actual gas release with proper
respiratory equipment and standby personnel.
Employees with personal monitors should be instructed to evacuate the area
immediately even if the low alarm is the only one to sound.
General Work and Hazardous Work Permit
Efforts shall be made to reduce H2S levels to below 10 ppm before
implementing H2S/RPE procedures.
If RPE is required because of H2S levels, appropriate management
authorization of the work should be required on the work permit. Second level
management review is recommended for IDLH (> 300 ppm) work.
No tank, valve, line, flange, relief vent, pig access, etc. which may create an
H2S concentration of 10 ppm or greater in the employee's breathing zone
shall be opened without proper RPE (G.1). The H 2S concentration in the
process stream should be considered when determining the potential for
exposure.
H2S procedures should always be employed if gas stream concentrations
exceed 300 ppm (volume) or 5 ppm (weight) in liquid streams regardless of
anticipated breathing zone levels.
Personal H2S instruments
Should be used by personnel not using RPE where there is a possibility that
the breathing zone concentration may exceed 10 ppm, unless fixed
monitoring is effectively employed at the facility/location. These areas should
be described in the written H2S program.
Some areas may include:
a. Catwalks and inside of firewalls of sour tanks
b. Sour crude tank batteries, well sites, and gas handling facilities
I14.6
I14.7
Emergency Procedures
The facility/location should have an Emergency Action Plan and procedures which
address H2S, including, at minimum:
Evacuation:
Evacuate personnel in a direction upwind or crosswind from the source to a
designated safe refuge;
Several selected areas of safe refuge for variable wind conditions;
Consider appropriate ventilation system scrubbers, air intake alarms,
automatic shutdown of air handlers, and RPE systems to protect those
personnel who can not evacuate the area, such as control room personnel.
Alarm Investigation
All alarms should be treated as an actual gas release.
Respiratory protection shall be worn when investigating alarms, and actual or
potential releases.
First Aid and Rescue
DO NOT INITIATE ANY RESCUE WITHOUT WEARING SCBA.
DO NOT ATEMPT ANY RESCUE IF YOU ARE NOT AUTHORIZED AND
TRAINED
A single standby person should not initiate rescue until radio contact has
been made and it is known that help is on the way.
After donning SCBA and calling for help, remove the victim from the area of
exposure.
First-Aid and medical treatment instructions: After removing the victim to a
safe location, clear the airway, begin mouth to mouth resuscitation. The
victim will die from lack of oxygen unless resuscitation is promptly and
successfully administered.
Administer oxygen if available and trained or qualified to do so.
Seek immediate medical attention.
I14.8
Lead Protection
Page: 1 of 15
Original: 01/01/2001
Revised: 01/01/2004
Lead Protection
Purpose
The purpose of this program is to establish and implement practices and procedures
for protecting the health of Moreno Group LLC and Subsidiaries employees who
may be exposed to lead on the job. This program also establishes methods for
complying with the OSHA Construction Industry Lead Standard, 29 CFR 1926.62.
Scope
The scope of this program applies to all Moreno Group LLC and Subsidiaries
projects and employees involved with lead paint removal projects and activities.
This program also applies to all subcontractors, working under the direct control of
Moreno Group LLC and Subsidiaries, involved with lead-based paint removal
projects and activities. Subcontractors must provide all manpower, supplies,
equipment, training, and medical examination and testing necessary to comply with
this program.
Responsibilities
The Facility Manager/Offshore Manager/Yard Foreman or Designee is
responsible for:
Informing the SH&E Department of any upcoming project that may have the
potential of containing lead
Inform any subcontractors that may be working on the project that the project
contains lead.
Ensure that subcontractors understand and comply with this policy as well as
the Lead Employee Project Specific Protection Plan.
The First Line Supervisor / Offshore Superintendent is responsible for
Understanding and complying with this policy/ procedure as well as the Lead
Employee Project Specific Lead Protection Program.
Designating employees for the project and ensuring that those employees all
go to the Human Resources Department to get an authorization to go to the
Medical Review Officer and receive initial blood lead levels prior to performing
any work on the project
I15.1
I15.2
Whenever workers airborne lead exposures exceed or are expected to exceed the
Action Level, the following will be implemented for the work project:
Competent person
Employee information and training
Employee medical surveillance
Airborne lead exposure monitoring
Record keeping
The Action Level may be exceeded where lead-containing coating or paint are
present and the following activities are performed: abrasive blasting, cleanup of
expendable abrasives, containment movement and removal, spray painting with lead
paint, manual scraping, manual sanding, power tool cleaning with and without dust
collection systems and heat gun applications. Some non-painting related activities
include: manual demolition of structures, welding, cutting, torch burning, rivet
busting, installation, removal, or demolition of lead containing materials, lead burning
and lead contamination/emergency cleanup operations.
Permissible Exposure Limit
The Permissible Exposure Limit (PEL) for airborne lead exposure is fifty (50) g/m ,
as an 8-hour TWA concentration.
This is the maximum 8-hour average
concentration of lead that an employee may be exposed to during each work day.
No employee will be exposed to airborne lead above the PEL without proper
protection.
The following methods will be used, as feasible and effective, for maintaining
airborne lead exposures below the PEL:
Engineering controls, such as general area ventilation for containments, local
exhaust ventilation for spot removal, vacuum blasting or vacuum equipped
power tools. When ventilation for containments is used, manometers and/or
velometers, will be used to evaluate the mechanical performance of the
ventilation system
Warning signs
Hygiene facilities and practices
Protective work clothing and equipment
Respiratory protection
Housekeeping
I15.4
During the period that respirators are worn, the protection factor of the specific
respirator may be used to determine employees exposure to airborne lead and to
achieve compliance with the PEL. The protection factors listed in the respirator
selection table of Moreno Group LLC and Subsidiaries Respiratory Protection
Program. For example:
Measured airborne lead concentrations at the workers breathing zone: 300
g/m ,8-hour TWA
Half-mask, air-purifying, negative pressure respirator with HEPA filters worn
all day: protection factor of 10
Employees daily lead exposure: 30 g/m
Competent Person
All work activities where employee airborne lead exposures may exceed the Action
Level will include a competent person in both the planning and performing stages of
projects involving lead exposure.
The competent person will be a person with training and experience in conducting
jobs involving lead exposure. The competent person will have the capability of
identifying hazards and the authority to take immediate action to eliminate them.
The competent person will be at the work site at all times while lead exposure
activities are in progress. They may have other job duties, but must be able to
monitor work continuously for hazards or deficiencies, and the authority to take
immediate corrective action.
Employee Information and Training
All employees who work on projects where airborne lead exposures are known to or
expected to be at or above the Action Level will be provided information and training
on the hazards of lead and measures for controlling these hazards and protecting
health.
Employees will receive initial comprehensive lead training before performing work
that may involve airborne lead exposure. This training will be repeated annually as a
refresher course.
The content of lead training will include:
The specific nature of activities or operations that may result in airborne lead
exposure above the Action Level
The health effects and risks of lead exposure
OSHA standards and guidelines for lead exposure
Engineering controls, including containments and ventilation systems
I15.5
I15.6
Warning Signs
Warning signs will be posted in the work area around activities where lead
exposures may exceed the Permissible Exposure Limit. The work area can be
demarcated by ropes, tape, walls, or containments.
Signs will be posted at every accessible side of the work area. These signs will be
easily visible from a distance so that employee can read the sign and take
necessary protective measures before entering the work area. Signs will read as
follows: WARNING, LEAD WORK AREA, POISON, NO SMOKING OR EATING.
The competent person will control access of persons into work area.
All persons entering work areas will wear protective clothing and respirators.
Eating, drinking, smoking, and chewing is prohibited in work areas and any area
where lead exposure may exceed the Permissible Exposure Limit.
Containments
Where required by federal, state, or local regulation, the project sponsor, or the
project owner, containments will be constructed and used as specified.
The purpose of containments is to restrict or prevent the spread of lead-containing
dust or debris to surrounding areas or the environment. While the proper use of
containments can help protect the public and the environment, they generally cause
a significant increase in airborne lead concentrations in the work area.
Containments may increase the potential for higher employee lead exposures.
Therefore, the use of well designed exhaust ventilation and the use of more
protective respirators may be necessary to properly protect workers.
Containments may include any of the following:
Rigid or flexible barriers or sheets surrounding the work area
Complete unventilated enclosures built around the work area
Complete enclosures maintained under negative pressure by exhaust
ventilation with exhaust air filtration
Containments may also require the construction and use of platforms or scaffolding.
These may be stationary or movable, ground supported or suspended.
Personal Hygiene Facilities and Practices
Clean change areas will be provided for all projects where employee airborne lead
exposures may exceed the Permissible Exposure Limit. These clean change areas
will be equipped with storage facilities for street clothing and a separate area for the
removal and storage of lead-contaminated clothing and equipment. This change
area will be designed and used so that contamination of street clothing does not
I15.7
occur. Airborne lead exposures in the change area will be maintained below the
Action Level.
Shower facilities will be provided for all projects where feasible when employee lead
exposures exceed the Permissible Exposure Limit. Shower facilities will comply with
the OSHA Standard, 29 CFR 1926.51, Sanitation. All employee whose airborne
lead exposures may exceed the Permissible Exposure Limit will shower or at a
minimum wash their hands and face at the end of each work shift. Employees
required to shower will not leave the workplace wearing any clothing worn while
performing lead exposure activities.
Clean lunch areas will be provided for all projects where employee airborne lead
exposures may exceed the Permissible Exposure Limit. Employee will remove or
clean their protective clothing and wash their hands and face before eating, drinking
or smoking. Airborne lead exposures in the lunch area will be maintained below the
Action Level.
An adequate number of clean lavatory and hand washing facilities will be provided.
These will comply with the OSHA Standard, 29 CFR 1926.51, Sanitation.
Where required by federal, state, or local regulation; the project sponsor; or the
project owner; decontamination units will be constructed and used as specified.
These generally are maintained under negative pressure and contain clean change
rooms, showers and dirty equipment rooms.
Protective Clothing and Equipment
Protective clothing and equipment will be worn by all employees whose airborne
lead exposures may exceed the Permissible Exposure Limit. Protective clothing and
equipment will be provided at no cost to the employee.
Protective clothing will include washable or disposable full body coveralls. Other
protective equipment will include faceshields, hats, gloves, shoes or disposable shoe
covers, eye protection, and hearing protection as appropriate.
Disposable protective clothing will be used for no more than one (1) work day. They
will be disposed of as lead-contaminated waste.
Reusable coverall will be collected at the end of each work day in closed containers.
Contaminated clothing will be cleaned by authorized laundries according to all
applicable federal, state, or local regulations pertaining to lead-contaminated laundry
and water discharge. All containers of lead-contaminated laundry will be labeled as
follows: CAUTION: CLOTHING CONTAMINATED WITH LEAD. DO NOT
REMOVE DUST BY BLOWING OR SHAKING.
DISPOSE OF LEAD
CONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL,
STATE OR FEDERAL REGULATIONS.
Reusable protective clothing (coveralls) will be laundered at least weekly, and clean
coveralls provided daily to employees whose exposure levels without regard to a
respirator are over 200 g/m3 of lead as an 8-hour TWA.
I15.8
Respirator Required
mask air purifying respirator with
HEPA filters2,3
mask supplied air respirator operated
in demand (negative pressure mode.)
Loose fitting hood or helmet powered
air-purifying respirator with HEPA
filters.3
Hood or helmet supplied air respirator
operated in continuous flow mode that
is type CE abrasive blasting respirators
operated in continuous flow mode.
Full facepiece air purifying respirator
with HEPA3
Tight fitting powered air-purifying
respirator with HEPA
I15.9
Moreno Group LLC and Subsidiaries, for the employees length of employment plus
30 years.
Other Relevant Information
The compliance program will be kept available at the work site for examination by an
affected employee or authorized person/agency.
The compliance program will be revised and updated at least annually.
I15.12
Attachment 1
I15.13
Medical Exam - Requirements for respirator users will include examinations and
tests as deemed necessary by the examining physician to ensure the ability to wear
and utilize respiratory protection. These tests will be provided annually to
employees assigned to wear a respirator.
Medical Examination for Lead Exposure
Frequency of Medial Examinations - Medical examinations will be provided at least
annually for each employee for whom a blood sampling test conducted at anytime
during the preceding twelve (12) months indicated a blood lead level at or above
forty (40) g/dl; as soon as possible, upon notification by an employee either that the
employee has developed signs or symptoms commonly associated with lead
intoxication; that the employee desires medical advice concerning the effect of
current or past exposure to lead on the employees ability to procreate a healthy
child, the employee is pregnant, or that the employee has demonstrated difficulty in
breathing during a respirator fit test or during use; and as medically appropriate for
each employee either removed from exposure to lead due to a risk of sustaining
material impairment to health, or otherwise limited pursuant to a final medical
determination.
Content of Medical Examinations - Medical examination will include, as a minimum:
A detailed work and medical history, with particular attention to past lead
exposure (occupation and non-occupational), personal habits (smoking,
hygiene), reproductive history and plans, and past problems involving the
cardiovascular, nervous or digestive systems, liver, kidneys, blood, or lungs.
A thorough physical examination with particular attention to the teeth, gums,
heart, lungs, digestive system, liver, kidneys, blood, and nervous system.
Pulmonary function test of forced vital capacity and forced expiratory volume.
Tests for blood pressure and resting heart rate.
Blood sample and analysis for blood lead level, hemoglobin and hematocrit
determinations, red cell indices, peripheral smear morphology, zinc
protoporphyrin, blood urea nitrogen, and serum creatinine.
Routine urinalysis with microscopic examination.
Other examinations or tests deemed necessary by the examining physician
Physicians Written Opinion - Medical Examinations
For each examination, Moreno Group LLC and Subsidiaries will obtain a written
opinion from the examining physician that contains the following:
I15.13.a.3
Whether the employee has a detected medical condition that places them at
an increased risk or health effects from exposure to lead
Any special protective measures to be provided to the employee or limitations
to be placed on the employees exposure to lead
Whether the employee is medically qualified to wear a respirator and any
limitations of use, especially concerning negative pressure respirators
A statement that the employee has been informed by the physician of the
results of the medical examination, blood tests, urine tests, and of any
medical conditions that may result from lead exposure
Moreno Group LLC and Subsidiaries will provide a copy of the examination and test
results and the physicians written opinion to the employee immediately after its
receipt.
Medical records of examinations and tests will be retained by Moreno Group LLC
and Subsidiaries for the employees length of employment plus 30 years.
Blood Lead Monitoring
Along with the initial and annual medical examinations have been addressed,
Moreno Group LLC and Subsidiaries will provide periodic blood sampling and
analysis for lead and zinc protoporphyrin levels to each employee exposed to lead
above the Action Level.
Blood lead analysis will be performed by laboratories licensed by the US Center for
Disease Control (CDC) or which has received a satisfactory grade in blood lead
proficiency testing from the CDC in the prior twelve (12) months.
Periodic blood lead monitoring will be provided every two (2) months for the first six
(6) months and every six (6) months thereafter to exposed employees during leadpaint removal projects, or more often if required.
Employees with blood lead levels above 40 g/dl but below 50 g/dl will continue to
be provided blood lead tests every two (2) months, until two (2) consecutive blood
lead levels are below 40 g/dl.
Employees who are identified with a blood lead level at or above fifty (50) g/dl will
be provided with a blood lead test within two (2) weeks. If the blood lead level
remains at or above fifty (50) g/dl, blood lead testing will be provided once a month,
until two (2) consecutive blood lead levels are less that forty (40) g/dl.
Employee will be informed in writing of their blood test results within five (5) working
days after receiving results. Employees will also be informed in writing that they
must be temporarily removed from lead exposure jobs and may be reassigned to
other duties at the site not involving lead exposure if their blood lead levels are at or
above fifty (50) g/dl. Anytime an employees blood lead level exceeds fifty (50)
g/dl, another blood lead test will be taken within two (2) weeks from the receipt date
I15.13.a.4
of the initial results. If both test results exceed fifty (50) g/dl the employee will be
temporarily removed and successive blood lead level tests will be made on a
monthly basis during the employees removal.
Medical Removal Program
Employees with blood lead levels at or greater that fifty (50) g/dl and as described
in Blood Level Monitoring will be temporarily removed from any work where airborne
lead exposure may exceed the Action Level. Workers will be removed from lead
exposures until two (2) consecutive blood lead samples show results below forty
(40) g/dl.
Employees determined, by a physician, to be at increased risk of health impairment
from exposure to lead will also be temporarily removed from any work where
airborne lead exposure may exceed the Action Level. Moreno Group LLC and
Subsidiaries will implement and act consistent with the physicians recommendations
for any special protective measures or lead exposure limitations for the employees.
Any employee temporarily removed from lead exposure activities due to elevated
blood lead levels or a physicians recommendations will be provided blood lead test
every four (4) weeks until two (2) consecutive tests indicate that blood lead levels
are at or below forty (40) g/dl.
Employees temporarily removed from lead exposure activities may be assigned to
other duties on-site that do not involve lead exposure above the Action Level.
Employees temporarily removed from lead exposure activities may return to their
normal lead exposure duties after two (2) consecutive blood lead tests indicate that
blood lead levels are at or below forty (40) g/dl.
I15.13.a.5
Attachment 2
I15.14
EQUIPMENT USED
EMPLOYEE NAME(S)
I15.14.a.2
I15.14.a.3
NORM Program
Page 1 of 42
Original: 03/01/2006
Revised: 09/08/2009
NORM Program
Purpose
The purpose of this program is to establish and implement practices and procedures
for protecting the health of Moreno Group LLC and Subsidiaries employees who
may be exposed to harmful levels of Naturally Occurring Radioactive Material
(ionizing radiation) encountered on the job. This program also establishes methods
complying with the OSHA construction industry radiation standard, 29 CFR
1910.1096 and LAC 33:XV.
Scope
The scope of this program applies to Moreno Group LLC and Subsidiaries
Environmental Divisions projects and employees involved with the maintenance,
cleaning, decontamination, land remediation, transportation, and handling of NORM
and TENORM contaminated material including but not limited to equipment,
tubulars, tanks, vessels and facilities. Also any land classified as NORM and
TENORM contaminated according to this program.
Responsibilities
The Facility Manager/Offshore Manager or Designee is responsible for:
Informing the SH&E Department and corporate RSO of any upcoming project
that may have the potential or has been clarified to contain NORM material or
action level NORM readings.
Purchase any radiological supplies as necessary and in accordance with
Moreno Group LLC and Subsidiaries purchasing procedure.
Inform any subcontractors that may be working on the project that the project
contains NORM and at what levels.
Ensure that subcontractors understand and comply with this policy as well as
the NORM employee project specific protection plan.
The Corporate Radiation Safety Officer (RSO) is responsible for:
The Corporate Radiation Safety Officer shall have overall responsibility and
charge of radiological conditions during activities performed under this
license. The corporate RSO may designate other RSOs to act in his absence
at the Moreno Group LLC and Subsidiaries NORM temporary jobsites. These
individuals, while acting in the capacity of an RSO, will be called NORM
I16.1
properly posted in accordance with this license and LAC 33:XV. He will also
ensure that individuals frequenting Restricted Areas are provided personal
dosimetry and adequate personal protective equipment to prevent NORM
contamination.
The RSO/NS is responsible for proper documentation of all safety meetings,
training, surveys, and control.
In the event of an emergency such as fire, accident, or uncontrolled NORM
release, the RSO/NS shall have authority to respond so as to minimize injury
to personnel or the environment. The corporate RSO shall be contacted
immediately.
Ensure that the requirements of this license, LAC 33:XV, 29 CFR, 10CFR,
and other pertinent rules, regulations, and orders are properly met and
implemented.
The Safety, Health and Environmental Department is responsible for:
Review the implementation of all safety requirements and procedures of all
personnel working in the area.
Review personnel training and knowledge of their duties and responsibilities.
Review the availability of necessary safety, personal protective and
environmental equipment and ensure that it is functioning and in good status.
Periodically inspect employee and contractors work habits to ensure that they
are working in a safety conscious manner.
Periodically inspect all equipment, plastic protective sheeting, storage areas,
containers, and other jobsite materials to ensure that they are properly
maintained in accordance with the applicable provisions of this license and
that NORM or other contaminants do not contaminate equipment, personnel,
or the equipment.
The First Line Supervisor / Offshore Superintendent is responsible for:
Qualifications are to include instructions in radiation safety practices
appropriate for operating procedures, knowledge of radiation regulations, and
on-the-job experience handling comparable materials. This individual will
have a minimum of 16 hours of instruction in radiation safety or 8 hours of
instruction in radiation safety and 40 hours of Hazardous Material safety
instruction. In addition, this individual will have a minimum of 3 months of
experience performing NORM decontamination procedures or 6 months of
experience handling Hazardous Materials. At a minimum, annual refresher
training will be required.
I16.3
Supervise all working personnel and all work activities taking place at the
jobsite.
Conduct safety meeting, at a minimum of the beginning of each job or when
additional (or new) personnel become necessary to perform work activities, to
inform employees and contractors of safety concerns and procedures prior to
the start of work.
Perform pre-job and daily/continual inspections of work site, equipment and
personnel work habits to ensure compliance with work plans, safety
standards and procedures, license specifications, and the LRR are being
followed. The inspections shall be documented on the Moreno Group LLC
and Subsidiaries NORM pre-job checklist and NORM daily checklist. (see
Attachments 1 & 2)
Shut down operational activities in the event of any emergency which could
result in injury to personnel or the environment.
All accidents and near misses are to be reported to the RSO and SH&E
Department.
Assist in preparing the daily RWP and associated paperwork required by this
license for the job and supply the RWP and associated paperwork to the
RSO.
The Personnel Working in Restricted/ Radioactive Areas are responsible for:
Facilities and areas where NORM contaminated equipment or waste is being stored,
utilized, or worked with shall be considered Radioactive Material Areas. A jobsite or
facility may be posted as a Radioactive Material Areas. A jobsite or facility may be
posted as a Radioactive Material Area and contain within it one or more Restricted
Areas. A Restricted Area is any area where access is controlled by the licensee for
purposes of protection of individuals against undue risks from exposure to radiation
and radioactive materials. The immediate area in which NORM activities are taking
place shall be considered Restricted Areas. Only individuals who have been
properly trained and/or informed regarding the risks associated with NORM and
proper handling of sources of radiation shall be allowed to work in Restricted Areas.
Individuals who perform the decontamination activities will have a minimum of
8 hours of instruction in radiation safety. In addition, these individuals will
have a minimum of 8 hours of on-the-job training in performing NORM
decontamination procedures. At a minimum, annual refresher training will be
required.
Visitor and short term contractors (contractors working less than one full day)
entering a Restricted Area will be briefed on the radiological health hazards
contained in the area, and made aware of precautions to be taken to minimize
their exposure. The guidelines used for this briefing shall be those contained
in LAC 33:XV.1012.
I16.4
Moreno Group LLC and Subsidiaries may employ contract labor for use in
operations involving NORM. These personnel, while not directly employed by
Moreno Group LLC and Subsidiaries, will be treated as employees for
purposes of training, worker protection, and qualifications.
All personnel working in a Restricted Area will be required to read and sign
the RWP prepared by the RSO/NS prior to commencing operations. The
RWP will describe authorized activities, personal protective equipment
required, and expected radiological and safety concerns. The RWP shall be
available for review at all times.
All personnel working in the Radioactive Materials/Restricted Areas shall
retain, at all times, Stop Work Authority. All employees will have not only
the right, but also the responsibility to immediately stop any operation or
evolution which may be dangerous to safety, health, equipment, and/or the
environment.
All personnel entering Restricted Areas will be required, as a minimum, to
perform a hand and foot frisk immediately upon exiting the Restricted Area.
A whole body frisk will be performed before leaving the work site and when
protective clothing was worn in the Restricted Area. Any reading above
background when performing a personal frisk shall be removed and the
person refrisked.
All accidents or injury, no matter how minor, will be reported to the designated
Work Supervisor, RSO/NS, and/or SH&E Department
All personnel working in Restricted Areas at temporary jobsites will hold Daily
SH&E Meeting. Meetings will include, but not limited to, a review of all
personnel concerns and the scheduled operations for the week (or day, as
appropriate), including any radiological hazards and concerns.
Requirements
HEALTH PHYSICS PROGRAM
BASIC PRACTICES AND GUIDELINES
Safety is of highest concern to Moreno Group LLC and Subsidiaries at all times, all
personnel will follow safe work procedures to protect themselves and their fellow
employees from direct contact with NORM and to prevent the release of NORM
contamination into the environment. All employees and contractors shall use, to the
extent practicable, procedures and engineering controls based upon sound radiation
protection principles to achieve occupational doses and public doses that are as low
as reasonable achievable (ALARA).
I16.5
PERSONNEL MONITORING
External Exposure
All personnel working in a Restricted Area shall be provided with personal
dosimetry devices to monitor the individuals received radiation dose.
Dosimeters will consist of either a film badge or thermoluminescent
dosimeter.
-
Taking into account that oilfield NORM does not normally exhibit
high radiation exposure levels, the annual occupational dose limit to
individual adults working under this license shall be that which is
the most limiting of: the total effective dose equivalent being equal
to 0.05 Sv (5 rem); or, the sum of the deep dose equivalent and the
committed dose equivalent to any individual organ or tissue other
than the lens of the eye being equal to 0.5 Sv (50 rem). In any
other circumstances, those limits as specified in LAC 33:XV.410
shall be utilized. Moreno Group LLC and Subsidiaries shall reduce
the dose that an individual may be allowed to receive in the current
year by the amount of occupational dose received while employed
by any other person(s)
Visitors and short term contractors (working less than 12 hours) entering a
Restricted Area will not be assigned dosimetry. These individuals will be
briefed, as described in LAC 33:XV.1012, on the radiological health hazards
I16.6
control of access;
limitation of exposure times;
use of respiratory protection equipment; or,
other controls.
Air sampling shall be conducted of the Restricted Area breathing zone of all
workers wearing respiratory protection at the direction of the RSO/NS and
boundaries of airborne-causing evolutions to ensure that no airborne
I16.7
Materials
The materials necessary to implement this procedure vary. The following list
serves as a guideline of items that may be kept on hand.
*
*
*
*
*
*
*
*
*
*
*
*
*
Philosophy
1) State and federal regulations state that respirators will be
prescribed only when it is likely that a potential for the
I16.9
of
process
and
I16.12
2) Seal Tests
(a) The wearer of a respirator shall ensure proper
protection by checking the seal of the facepiece prior
to each use by performing a negative pressure seal
test.
(b) The negative pressure seal test is performed by
covering the respirators canister or filter inlets with
the palms of the hands. The wearer then inhales
gently and holds his breath for at least 10 seconds. If
the facepiece collapses slightly and no inward
leakage of air into the respirator is detected, the fit is
considered satisfactory.
(c) No one is authorized to use any respirator without first
performing a satisfactory face seal test.
3) Relief From Use
(a) Each and every respirator user may leave the area at
any time for relief from respirator use in the event of
equipment malfunction, physical or psychological
distress, procedural or communication failure,
significant deterioration of operating conditions, or any
other condition that might require relief.
(b) Relief from use will be included as part of the pre-job
brief.
- Air Monitoring
Air monitoring will be conducted as needed.
- Medical Evaluations
1) Physicals
(a) Employees will be evaluated by competent medical
personnel to ensure that they are physically and
mentally able to perform work while wearing
respiratory protection equipment.
(b) These evaluations will be performed initially and at
least annually thereafter.
(c) Records of these physicals shall be maintained at
Moreno Group LLC and Subsidiaries for not less than
5 years.
I16.13
- Respirator Maintenance
1) Respirators will be inspected prior to each use, when
cleaned and both during and after the days work. Any
respirator not in working condition will be removed from use
and repaired or replaced.
2) Respirators will be cleaned after each use with alcohol or
other suitable swabs. At the end of the work shift, the
respirators will be washed in soapy water and let to dry.
3) Respirators will be maintained in bags or some other
protective enclosure to ensure that they do not become
contaminated. They shall be stored in a clean, dry area,
preferably out of direct sunlight.
ALARA PROGRAM
Philosophy
Moreno Group LLC and Subsidiaries will maintain all exposure to personnel and the
environment ALARA (as low as reasonable achievable). This will be accomplished
by minimizing personnel time spent in the vicinity of radioactive sources and by
maximizing distance from radioactive sources. ALARA practices will also include
necessary surveys, safety/radiological meetings, and other measures to track,
control, and dispose of NORM appropriately and in accordance with the radiation
protection philosophy of this license and existing regulations.
Program Structure and Responsibilities
The ALARA program consists of all Moreno Group LLC and Subsidiaries personnel:
workers (both employee and Contractor), supervisors and management.
I16.14
All Moreno Group LLC and Subsidiaries personnel shall adhere to the
rules and procedures established by the RSO/NS. The worker must
report any unsafe work practices and/or equipment malfunctions that
could result in any increase of radiological hazard to the RSO/NS or his
designee. The worker may also make suggestions as to improve the
ALARA program.
Administrative Procedures
-
NORM training shall include reference to this program and the concepts
this program is based on.
Written Procedures
Standard procedures shall be written for all practices involving the handling,
processing, and temporary storage of NORM. These procedures should contain
proper radiation work practices to minimize exposure during all NORM activities.
Operating Procedures
The ALARA program shall be maintained while performing NORM activities at the
Moreno Group LLC and Subsidiaries temporary jobsites. It is the responsibility of
each individual to adhere to procedures for safe radiological work practices.
I16.15
ACCIDENTS
In the event of an accident, fire, release, or spill, the RSO/NS will be immediately
notified. First priority will always be given to injured personnel. Radiological
concerns will be addressed only after conditions involving personnel, fires,
uncontrolled releases, or spills have been stabilized. In the event of a spill, the
person discovering it shall immediately implement the Spill Contingency Plan in
Section 11.0 of this license.
I16.16
Moreno Group LLC and Subsidiaries shall prepare any report filed to
LDEQ/RPD so that names of individuals who may have received exposure
to radiation are stated in a separate and detachable portion of the report.
Notification of Incidents
-
Given that oilfield NORM should not reach elevated levels of exposure,
should it occur, Moreno Group LLC and Subsidiaries will follow the
procedures listed in LAC 33:XV.486 and 487.
I16.18
It will include waste generating activities from the Moreno Group LLC and
Subsidiaries temporary jobsites within LDEQ/RPD jurisdiction.
The report shall list the customer (or generator) name, jobsite location,
dates of job, amount of waste generated, and the date the waste was
transferred.
I16.19
I16.20
The Restricted Area boundary surveys shall be conducted before, during, and
after all work activities involving NORM operations. A minimum of one
radiation and contamination boundary survey shall be conducted each day at
temporary jobsites. Additional surveys shall be conducted as warranted by
the work activities and as directed by the RSO.
Survey results shall be documented on a jobsite sketch or map and reported
to the RSO. Records of surveys shall be maintained for a period of not less
than 5 years at Moreno Group LLC and Subsidiaries
EQUIPMENT CONTAMINATION SURVEYS
Wipe Tests
-
Only those persons who have received, at a minimum, proper training for
NORM surveying will be allowed to conduct wipe testing of equipment, etc.
A Ludlum Model 2 survey meter outfitted with a Ludlum Model 44-9 probe (or
equivalent instrumentation) shall be used to measure the wipes. Other
information on instrumentation can be found in Section 9.0 of this license.
After the wipe has been taken, it will be brought to an area of low background
(equal to or less than 50 cpm) and counted with the instrumentation listed
above. Taking into account the instrument efficiency, add the background
reading to the action level of 100 cpm to get a true action level. Items with
loose surface contamination exceeding this true action level will be handled
as NORM contaminated and appropriate action taken. If the item has been
verified free of loose surface contamination, the item shall be taken to an area
of low background and surveyed for fixed contamination over 100% of all
accessible surfaces. Any item found to have fixed contamination exceeding
levels for unrestricted use, or as directed by the customer, shall not be
released for such use. Should the item contain levels exceeding those
specified in LAC 33:XV.1404, it shall be handled and controlled as NORM
contaminated.
Only those persons who received, at a minimum, proper training for NORM
surveying shall be allowed to perform personal frisks.
Personal Frisking Procedures
-
The probe shall be held within of the body and moved at a rate of 2 3
inches per second. Any sustained readings above background shall be
cause to slow or stop the probe over the affected area for adequate
measurement. Should the reading persist, the contamination in that area
shall be removed and the person refrisked.
contamination
occurred
and
the
I16.22
After completion of the Incident Report Form, the RSO/NS shall review the
form with the individual. The individual will counter-sign the form
indicating the information contained on the form is true and correct to the
best of his knowledge.
Appropriate sampling tools (i.e., shovel, trowel, auger, coring device, etc.)
shall be utilized to retrieve representative samples at the appropriate
depths. Tools will be wiped and cleaned between samples to prevent
possible cross contamination.
Each sample shall be placed into a suitable container (i.e., Ziploc bag,
plastic wide-mouth container, etc.) and labeled including customer name,
date, project number, sample number, sample location, contents, and any
other appropriate markings for shipping protocol.
WATER SAMPLING
Wash water
-
Any surface (or ground) water that may accumulate in a low or remediated
area of known NORM contamination shall be pumped into appropriate
I16.23
containers. The water will be filtered to remove particulates and recycled for
further wash down activities. It will also be considered NORM waste until a
laboratory analysis proves otherwise.
Sampling procedures
-
A dose rate survey shall be performed on the lands, equipment, and well
head found on the work site.
a) The survey will be documented on gridded survey maps or plats.
The maps shall be constructed so that grid locations can be easily
identified and referenced. All notes and other information not
recorded directly on the map should be referenced to grid locations.
Maps should be of sufficient size and scale to contain all survey
information, sample locations, and all significant objects.
I16.24
A copy of the baseline dose rate survey shall be retained on the temporary
jobsite for the duration of the project for review by the RSO/NS, other
employees & contractors, and the LDEQ.
valves, flanges, pumps, and containers are not leaking NORM or other
contaminants to the environment.
Per existing regulations and conditions of this license, only properly briefed
and/or trained individuals shall be allowed to work with NORM.
A boundary shall be established around the jobsite and posted with
appropriate signs as specified in LAC 33:XV.450, 451 & 452 and Section 5.2
of this license. The signs shall bear the conventional radiation colors
(magenta, purple, or black on a yellow background) and the three blade trifoil design. As a minimum, the sign shall bear the words Caution
Radioactive Materials.
Additional postings such as Radiation Area,
Airborne Radioactivity Area, Restricted Area, etc. may be required
depending upon other activities taking place.
The area posted and controlled as a Restricted Area shall be kept as small as
possible. However, the area will be large enough to allow for all work and transit of
personnel and equipment to be performed in a safe manner.
No eating, drinking, smoking, or chewing will be allowed within the Restricted
Area or Radioactivity Area. Open wounds, sores or cuts shall be reported to
the RSO/NS and covered with bandages and/or protective clothing prior to
working in the Restricted Area or Radioactivity Area.
The provisions of the RWP shall be carried out which delineates, among other
things, personal protection requirements as specified in the Health Physics
section of this license.
Depending on the site conditions and layout, plastic sheeting, rubber or
plastic mats, drip pans, cement or plastic lined slabs, or other non-permeable
material shall be used to minimize the potential spread of contamination.
A point of entry and egress from the Restricted Area shall be designated and
established based on several conditions, not the least of which concerns
personal and environmental safety. As stipulated in the license, all personnel
exiting controlled areas will perform a personal frisk to ensure that
contamination is not being removed from the controlled area and that the
individual is not contaminated.
All containers and equipment used in NORM work activities will be wiped or
smeared for loose surface contamination per the license. They will not be
released for unrestricted use should those levels reach or exceed twice
background.
Prior to being released for unrestricted use, facilities, equipment, or sites shall
be decontaminated in accordance with this license and current LRR.
As directed by the RSO/NS, radiation & contamination surveys shall be
performed or controlled areas at temporary jobsites.
They shall be
I16.27
I16.28
All items received shall be randomly surveyed for radiation levels and loose
surface contamination. Items having loose surface contamination shall be
controlled and worker protection measures placed in effect (i.e., protective
clothing, sealing exposed openings with plastic or other suitable materials
preventing the spread of contamination) until such time that the items have
been moved into a decontamination area and/or decontaminated. In addition,
trucks, boats, or other vehicles transporting the NORM shall be surveyed for
loose surface contamination and shall not be released for unrestricted use
until verified free of contamination.
Records shall be kept of NORM contaminated equipment and materials
received and shall include, but not be limited to:
-
the name, address, phone, and general license number of the generator;
the maximum dose rate obtained from the random survey of the external
surface of the material the NORM is contained in;
On
During the inspection, the designated individual shall look for leaking or deteriorating
containers, labels, and the condition of materials preventing the spread of
I16.29
(504) 751-5893
(713) 280-9982
(915) 235-5494
(800) 824-4250
Each survey instrument shall be calibrated: at intervals not to exceed one year; any
time the instrument is found to respond inconsistently to a known source; when it
shows any indication of physical damage; after each instrument servicing; at
energies and radiation levels appropriate for use; and, so that accuracy within plus
or minus 20 percent of the true radiation level can be demonstrated on each scale.
I16.31
I16.32
Warn others. It is the responsibility of the person noticing the spill to warn
others in the vicinity of the spill of the danger and ensure that the RSO/NS is
notified of the occurrence as soon as possible.
Isolate the area. It is the responsibility of the personnel combating the spill to
contain the spill and isolate the area of occurrence to prevent possible
inadvertent personnel contamination.
Minimize the spill spread and personnel exposure. Every effort shall be made
by the personnel combating the spill to contain the spill to as small an area as
possible. Additionally, the personnel will take steps to minimize their
exposure. Exposure to NORM contaminants can be prevented through use
of appropriate protective clothing. Other measures may be taken as noted in
the license and/or as directed by the RSO/NS.
Secure operations. All operations which could possible result in the spread of
the spill, or which could cause the spilled effluents to become airborne, shall
be immediately stopped.
NOTIFICATION REQUIREMENTS
The RSO/NS on duty will be responsible for determining which spills and
incidents need to be reported to the corporate RSO. The corporate RSO
shall
then determine if the spill or incident needs to be reported to LDEQ/RPD in
accordance with LRR. These spill or incidents shall be reported to:
STATE OF LOUISIANA
Department of Environmental Quality
Office of Air Quality and Radiation Protection
Radiation Protection Division
P.O. Box 4313
Baton Rouge, LA. 770821-4313
(225) 765-0160
Additionally, the RSO/NS shall determine if it is necessary to contact one or
more of the members of Moreno Group LLC and Subsidiaries Radiation
Safety Committee. The following names are listed in order of priority for
contact.
Corporate Radiation Safety Officer ........ Alan Tasar
Work:
337-364-7170
Cell
337-577-4994
Environmental Manager ......................... Anthony Sagrera II
Work
337-364-7170
Cell
337-298-8615
I16.34
The name of the person reporting the spill / incident and a telephone
number where he may be reached.
Time and date the spill / incident began and ended, or the estimated time
of continuation of discharge of the material
Within seven (7) days following a verbal report, a written report shall be
submitted to LDEQ/RPD. The written report shall include:
-
Time and date of the verbal notification and name of the person who made
the verbal notification.
Details of the circumstances and events that caused the spill / incident.
SPILL CLEANUP
In the unlikely event that a spill might migrate or occur over unprotected land, the
contaminated soil shall be removed in accordance with the license and shall be
returned to the client as part of the decontamination project for temporary storage or
disposal. Cleanup will continue until the area is cleaned to background (or baseline)
levels.
OPERATING PROCEDURES
Moreno Group LLC and Subsidiaries shall follow all applicable state and federal
rules and regulations in addition to the policies and procedures contained in this
I16.35
The air tool scrapes the internal surface of the tubular using centrifugal
force to remove the scale. The NORM particles are sent to a collection
chamber from where the air is filtered prior to release into the atmosphere.
Heat may be applied to the tubular surface to remove the moisture from
the NORM scale effectively causing it to flake off. Small hand tools may
also aid the removal of fixed NORM contamination.
Moreno Group LLC and Subsidiaries These records shall be kept legible and
shall include, but not be limited to, the following:
-
Those that will be maintained for a period of not less than five (5) years.
a) Training records of all personnel; briefs & instructions given to
visitors & short term contractors.
b) Inventory and manifests reflecting all material processed at the
temporary jobsites. This shall include the generator of origin, date
shipment was received, the number of drums or packages
received, and the maximum dose rate readings and smearable
contamination reading on each drum or package.
c) Instrumentation calibration records.
d) Radiation and contamination surveys conducted by Moreno Group
LLC and Subsidiaries at the temporary jobsites. This includes
decontamination, spill/cleanup operations and environmental
monitoring, such as air and soil laboratory results.
Those that must be kept indefinitely either by Moreno Group LLC and
Subsidiaries or, at termination of this license, by making provisions with
LDEQ/RPD for transfer to the division.
e) Personnel monitoring data.
f) Results of surveys used to evaluate the release of NORM effluents
into the environment.
g) Records of disposal of radioactive material.
I16.40
Form DRC-3
Attachment 1
I16.41
NORM
Pre-Job Checklist
Job Name:
Job #:
Date:
__________________________
Job Description:
__________________________ Job Locations:
Customer Representative:(Print)
#
Task/Item
1
2
3
Initials
Verify planned activities and isotopes are authorized IAW License Number
Submit RPD - 35. Temporary Jobsite Notification to LDEQ
Gather required records
RPD - 35. Temporary Jobsite
Notification to LDEQ
Ensure required records are current (training, calibration certificates, physicals, etc
Respirator Wipes
Radioactive Material Labels
I16.41.a.1
Attachment 2
I16.42
NORM
Daily Checklist
Job Name:
Job Description:
#
1
2
3
4
5
Job #:
Date:
__________________________
__________________________ Job Locations:
Task/Item
6
7
8
9
10
11
12
13
14
15
16
Initials
I16.42.a.1
Respiratory Protection
Page: 1 of 21
Original: 01/01/2001
Revised: 06/01/2008
Respiratory Protection
Purpose
The purpose of Moreno Group LLC and Subsidiaries respiratory protection program
is to establish and set guidelines for the selection of respiratory equipment,
situations for its use, and training in the use of the respirator selected.
Scope
It is the policy of Moreno Group LLC and Subsidiaries to maintain and implement a
Respiratory Protection Program that will ensure employee respiratory protection for
routine, and non routine activities when feasible engineering controls or work
practices are not adequate or available to control exposure to airborne
contaminants.
Whenever possible, effective engineering controls shall be used to control employee
exposure. Effective engineering controls include enclosure or confinement of the
operation, general and local ventilation, and substitution of less toxic materials.
When not feasible, or while instituting controls, appropriate respiratory protection
should be use as described in this program.
Administration
Moreno Group LLC and Subsidiaries Management will have the primary
responsibility for administering and updating the Respiratory Protection Program.
The following portions of the program may be delegated to the Safety, Health and
Environmental Department; program evaluation, employee training, fit testing,
procedures for selecting a respirator and use, and respirator hazard determination.
The following portion shall be administered by the supervisor; respirator use in
surveillance areas, respirator purchasing and inventory and respirator
maintenance(i.e. cleaning, storage, inspection and repair).
Responsibilities
The Facility / Site Manager or Designee is responsible for:
Evaluating the respiratory hazards at their facility / site and the protective
equipment required.
Obtaining the assistance of an outside consultant whenever necessary to
satisfy the requirements of this Procedure.
I17.1
I17.2
Filtering facepiece (dust mask) means a negative pressure particulate respirator with
a filter as an integral part of the facepiece or with the entire facepiece composed of
the filtering medium.
Fit factor means a quantitative estimate of the fit of a particular respirator to a
specific individual and typically estimates the ratio of the concentration of a
substance in ambient air to its concentration inside the respirator when worn.
Fit test means the use of a protocol to qualitatively or quantitatively evaluate the fit of
a respirator on an individual. (See also Qualitative fit test QLFT and Quantitative fit
test QNFT.)
Helmet means a rigid respiratory inlet covering that also provides head protection
against impact and penetration.
High efficiency particulate air (HEPA) filter means a filter that is at least 99.97%
efficient in removing monodisperse particles of 0.3 micrometers in diameter. The
equivalent NIOSH 42 CFR 84 particulate filters are the N100, R100, and P100 filters.
Hood means a respiratory inlet covering that completely covers the head and neck
and may also cover portions of the shoulders and torso.
Immediately dangerous to life or health (IDLH) means an atmosphere that poses an
immediate threat to life, would cause irreversible adverse health effects, or would
impair an individual's ability to escape from a dangerous atmosphere.
Loose-fitting facepiece means a respiratory inlet covering that is designed to form a
partial seal with the face.
Negative pressure respirator (tight fitting) means a respirator in which the air
pressure inside the facepiece is negative during inhalation with respect to the
ambient air pressure outside the respirator.
Oxygen deficient atmosphere means an atmosphere with oxygen content below
19.5% by volume.
Physician or other licensed health care professional (PLHCP) means an individual
whose legally permitted scope of practice (i.e., license, registration, or certification)
allows him or her to independently provide, or be delegated the responsibility to
provide, some or all of the health care services required by this program.
Positive pressure respirator means a respirator in which the pressure inside the
respiratory inlet covering exceeds the ambient air pressure outside the respirator.
Powered air-purifying respirator (PAPR) means an air-purifying respirator that uses a
blower to force the ambient air through air-purifying elements to the inlet covering.
Qualitative fit test (QLFT) means a pass/fail fit test to assess the adequacy of
respirator fit that relies on the individual's response to the test agent.
I17.5
Quantitative fit test (QNFT) means an assessment of the adequacy of respirator fit
by numerically measuring the amount of leakage into the respirator.
Respiratory inlet covering means that portion of a respirator that forms the protective
barrier between the user's respiratory tract and an air-purifying device or breathing
air source, or both. It may be a facepiece, helmet, hood, suit, or a mouthpiece
respirator with nose clamp.
Service life means the period of time that a respirator, filter or sorbent or other
respiratory equipment provides adequate protection to the wearer.
Supplied-air respirator (SAR) or airline respirator means an atmosphere-supplying
respirator for which the source of breathing air is not designed to be carried by the
user.
Tight-fitting facepiece means a respiratory inlet covering that forms a complete seal
with the face.
User seal check means an action conducted by the respirator user to determine if
the respirator is properly seated to the face.
Requirements
Respirator Selection Procedures
Respirators used in the work place are selected based on:
A reasonable estimate of employee exposure to respiratory hazards and
Relevant work place and user factors.
Where the employee exposure cannot be identified or reasonably estimated, the
atmosphere shall be considered IDLH.
Respirators selected shall be NIOSH certified and used within the conditions
of the NIOSH certification.
The number of respirator models and sizes offered by Moreno Group LLC
and Subsidiaries will be sufficient to correctly fit any user.
Respiratory Hazard Evaluation
The employee respiratory hazard evaluation and identification of relevant workplace
and user factors may be found in the Attachments. The evaluation shall be updated
when new hazards or exposures are identified or job descriptions or job tasks
change.
The table within Attachment 1 was developed from the evaluation and lists respirator
and cartridge selection based on the evaluation. After any update of the hazard
I17.6
evaluation the following table will be updated and the Respiratory Protection
program will be amended.
The following table lists the respirators by job description and task. With each job
and respirator listed is the associated contaminant for which the respirator is
authorized and the cartridges required change schedule (maximum use time limit).
Respirator Use In Non-IDLH Atmospheres
Compliance with all OSHA statutory and regulatory requirements, under routine and
reasonably foreseeable emergency situations shall be provided.
Moreno Group LLC and Subsidiaries requirements include Lead, 29 CFR
1910.1025 and Air Contaminants, 29 CFR 1910.1000.
The respirator shall be appropriate for the chemical state and physical form of
the contaminant.
Respirator Change Schedule
The change schedule is weeks equivalent replacement of the cartridge unless
required earlier by contaminant breakthrough suspicion or potential equipment
performance deterioration. Weeks equivalent means 40 hours of continuous use.
When the painting workload is heavier than normal and the respirator change
schedule based on weeks equivalent is suspect, the cartridge replacement cycle
will be reduced an appropriate amount.
When equipment inspection reveals the performance of the respirator is diminished,
such as, but not limited to head band elastic loss, valves not sealing, the respirator
will be replaced.
Change Schedule Basis
The change schedule is based on a combination of manufactures
recommendations, employee historical evidence of breakthrough-suspicion and preand post-use inspection observations.
Cartridges shall be selected from:
NIOSH certified HEPA,
Filter certified for particulates by NIOSH under 42 CFR part 84, or
Any filter certified by NIOSH for particulates.
I17.7
I17.8
I17.9
Medical Determination
Moreno Group LLC and Subsidiaries shall do the following to determine an
employees ability to use a respirator.
Obtain the PLHCPs written recommendation regarding the employees ability
to use the respirator. Include only the following in the recommendation.
Any respirator use limitations due to medical condition or work place
conditions including the employees fitness to wear the respirator.
The need for follow-up medical evaluations if required, and
A PLHCPs statement the employee was provided with a copy of the
PLHCPs written recommendations.
For negative pressure respirator use, a negative finding by the PLHCP or
other qualified person means Moreno Group LLC and Subsidiaries will:
Examine the reason for the negative finding with the help of the PLHCP or
other qualified person.
Investigate alternative respiratory protection.
Provide alternative respiratory protection as required to ensure the employee
is provided with adequate respiratory protection.
Additional Medical Evaluation
An additional medical evaluation will be provided to employees under the following
conditions:
The employee reports medical signs or symptoms that are related to the
ability to use a respirator,
A PLHCP, Superintendent, Foreman, or the program
determines that an employee needs to be reevaluated,
administrator
I17.10
I17.11
Quantitative fit testing shall require sampling inside the facepiece midway
between the nose and the mouth of the employee. Modification of the
employees respirator with a temporary sampling adapter or surrogate
respirator modification to accept a permanent sampling probe is required.
Respirator Use Procedures
Procedures include proper use for routine and reasonably foreseeable emergency
situations. The following procedures establish proper use of respirators. Procedural
requirements include:
Prohibiting facepiece seal leakage,
Preventing removal of respirators in hazardous environments,
Ensuring continued effective respirator operation throughout the work shift,
And
Preventing use of respirators in IDLH atmosphere without approval of the
administrator and prior development of specific written procedures.
Facepiece Seal Protection
Conditions That Will Prevent Employees Wearing Tight -Fitting Facepiece
Respirators
When facial hair comes between the sealing surface of the facepiece,
When facial hair interferes with valve function, and
When any condition interferes with the face-to-facepiece seal or valve
function.
Ensure Tight Fitting Respirator Seals To The Employees Face
Ensure corrective glasses or goggles or other personal protective equipment
is worn in a manner that does not interfere with the seal of the facepiece to
the face.
Ensure the employee performs a user seal check each time the respirator is
put on. Use the following procedure. The user seal check is not a substitute
for qualitative or quantitative fit testing.
I17.12
I17.13
I17.14
Storage
Employees shall store respirators as follows:
Respirators shall be protected from damage, contamination, dust, sunlight,
extreme temperatures, excessive moisture, and damaging chemicals, and
they shall be packed in a container to prevent deformation of the facepiece
and exhalation valve.
Emergency respirators shall not be routinely used by Moreno Group LLC and
Subsidiaries employees. In the event that the administrator deems they are
necessary for non-routine work, the program administrator shall provide a
procedure for respirator use consistent with the OSHA Respiratory Protection
Regulation, 29 CFR 1910.134.
Inspection
Respirators shall be inspected by the employee as follows:
Respirators shall be inspected before each use and during cleaning.
Respirator inspections shall include the following:
Check for function, tightness of connections, and the condition of the
various parts including, but not limited to, the facepiece, head straps,
valves, connecting tube, and cartridges, and filters.
Check plastic and rubber parts for pliability and signs of deterioration.
Repairs
Respirators that fail inspection or are otherwise defective shall be removed
from service and discarded, repaired, or adjusted.
Respirator repair shall be performed by Program Administrator authorized
persons.
Authorized persons include Safety Department Safety Managers or
coordinators or persons working directly under the manager or
coordinators direction.
Repairs shall be made according to the manufacturers recommendations
and specification for the type and extent of repairs to be performed. At no
time shall respirator parts for one make or type respirator be used on a
respirator of another make or type.
I17.15
I17.18
I17.19
Record Keeping
Records must be maintained for medical evaluations, fit testing, and the respirator
program. The records shall be available to facilitate employee involvement in the
program, assist in auditing adequacy of the program and provide a record for
compliance determinations by OSHA.
Medical Records
Ensure records are retained and made available in accordance with 29 CFR
1910.1020.
Fit Testing
Ensure records of qualitative and quantitative fit tests administered to
employees are retained including:
Name or identification of employee tested.
Type of fit test performed
Specific make, model, style, and size of respirator tested,
Date of test, and
Pass/fail result for QLFTs or the fit factor and strip chart recording or other
recording of the test results of QNFTs.
Fit test records shall be retained for respirator users until the next fit test is
administered.
Note: Moreno Group LLC and Subsidiaries Inc. reserves the right to change this
policy at their discretion.
Written Respiratory Protection Program
A written copy of the current program shall be retained by the Program
Administrator. Current copies shall be distributed as needed to First Line
Supervisors and Offshore Superintendents and foremen who have respirator users.
I17.20
Attachment 1
I17.21
Job Description
Onshore Painter
Onshore Painter
Blaster
Job Task
Contaminant
Maximum Change
Schedule
8 hour or
breakthrough
-3M
8 hour or
breakthrough
Blasting
Silica,Quartz,Cristobalite,Trydimite,Respirable
dust
8 hour or
breakthrough
Paint
Mixing/Cleaning
I17.21.a.1
The following table lists the respirators by job description and task. With each job and respirator listed is the associated contaminant for which the
respirator is authorized and the cartridges required change schedule (maximum use time limit). Respirator Selection Table for all Moreno Group LLC and
Subsidiaries Locations (onshore and offshore)
Job
Description
Onshore
Painter
Offshore
Painter
Job
Task
Paint
Paint
Onshore
Painter
Mixing/Cleaning-3M
Offshore
Painter
Mixing/Cleaning-3M
Helper
Welder
Helper
Welding help
Welding
Welding help
Blaster
Blasting
Welder
Welding in Confined
Space
Contaminant
Maximum Change
Schedule
Inorganic Zinc
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
Inorganic Zinc
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
Organics, Fumes
8 hour or breakthrough
Hexavalent Chromium
8 hour or breakthrough
N/A
I17.21.a.2
Welding on Stainless
Steel or Exotic Metals
Job Task
Assist with first flange
break
Helper
Boilermaker
Welding help
Contaminant
Benzene > 1ppm - <25ppm
Benzene >25ppm - <50ppm
HF Acid >3ppm - < 6ppm
H2S >5ppm- < 15ppm
Benzene >50ppm
HF Acid >6ppm
H2S >15ppm
Unknown concentration of any
of the above contaminants
Zinc
Galvanize/Lead
Benzene > 1ppm - <25ppm
Benzene >25ppm - <50ppm
HF Acid >3ppm - < 6ppm
H2S >5ppm <15ppm
Benzene >50ppm
HF Acid >6ppm
H2S >15ppm
Inorganic Zinc
Epoxies (incl. coal tar)
VOC based paints
Urethanes
Solvents
Galvanize/Lead
Organics, Fumes
Painter
Mixing/Cleaning-3M
Welder
Welder
Welding
Welding in Confined Space
Welder
Hexavalent Chromium
Pipe Fitter
Welding help
Pipe Fitter
Welding help on Stainless Steel or 3M 6101 with P-100 filter - also refer to Hexavalent
Exotic Metals
Chromium Program.
Blasting
Supplied Air Blasthood
Zinc
Galvanize/Lead
Hexavalent Chromium
Blaster
Supplied Air
Work on process
pumps
Maximum Change
Schedule
8 hour or breakthrough
8 hour or breakthrough
N/A
8 Hours or breakthrough
8 Hours or breakthrough
8 Hours or breakthrough
N/A
8 Hours or breakthrough
8 Hours or breakthrough
8 Hours or breakthrough
8 Hours or breakthrough
8 Hours or breakthrough
8 Hours or breakthrough
8 Hours or breakthrough
8 hours or breakthrough
8 Hours or breakthrough
8 hours or breakthrough
N/A
N/A
8 hour or breakthrough
8 hour or breakthrough
N/A
I17.21.a.3
Insulator
Asbestos Abatement
Carpenter
Spray Painting
Organic Vapor
8 hour or breakthrough
All Trades
Mold Abatement
Tank Cleaning
* (Confined Space)
Tank Cleaning
(From Outside)
8 hour or breakthrough
Environment
NA
8 hour or breakthrough
Rescue
Environment
NA
Cleaning Tech
Cleaning Tech
Cleaning Tech
I17.21.a.4
Assigned Protection Factors (APFs) Employers must use the assigned protection factors
listed in Table 1 to select a respirator that meets or exceeds the required level of employee
protection. When using a combination respirator (e.g., airline respirators with an air-purifying
filter), employers must ensure that the assigned protection factor is appropriate to the mode
of operation in which the respirator is being used.
Table 1. -- Assigned Protection Factors5
Type of respirator1, 2
Quarter
Half
Full
Helmet/
Loosemask
mask
facepiece
hood
fitting
facepiece
3
1. Air-Purifying Respirator
5
10
50 .............. ..............
2. Powered Air-Purifying
..............
50
1,000 425/1,000
25
Respirator (PAPR)
3. Supplied-Air Respirator
(SAR) or Airline Respirator
Demand mode
..............
10
50 ..............
..............
Continuous flow mode
..............
50
1,000 425/1,000
25
Pressure-demand or
..............
50
1,000 ..............
..............
other positive-pressure
mode
4. Self-Contained Breathing
Apparatus (SCBA)
Demand mode
..............
10
50
50
..............
Pressure-demand or
.............. ..............
10,000
10,000
..............
other positive-pressure
mode (e.g., open/closed
circuit)
Notes:
1
Employers may select respirators assigned for use in higher workplace concentrations of a
hazardous substance for use at lower concentrations of that substance, or when required
respirator use is independent of concentration.
2
The assigned protection factors in Table 1 are only effective when the employer
implements a continuing, effective respirator program as required by this section (29 CFR
1910.134), including training, fit testing, maintenance, and use requirements.
3
This APF category includes filtering facepieces, and half masks with elastomeric
facepieces.
4
The employer must have evidence provided by the respirator manufacturer that testing of
these respirators demonstrates performance at a level of protection of 1,000 or greater to
receive an APF of 1,000. This level of performance can best be demonstrated by
performing a WPF or SWPF study or equivalent testing. Absent such testing, all other
PAPRs and SARs with helmets/hoods are to be treated as loose-fitting facepiece
respirators, and receive an APF of 25.
5
These APFs do not apply to respirators used solely for escape. For escape respirators
used in association with specific substances covered by 29 CFR 1910 subpart Z,
employers must refer to the appropriate substance-specific standards in that subpart.
Escape respirators for other IDLH atmospheres are specified by 29 CFR 1910.134 (d)(2)
I17.21.a.5
Page:
Original: 01/01/2010
Revised:
J1.2
Reading and being familiar with the manual for the equipment being operated
and operating the equipment as intended by the manufacturer.
Never operating equipment that is unsafe and in need of repair.
Performing and documenting the pre-use / shift inspection.
Check brake operation, by lifting load a short distance and releasing control.
Be aware of shut-off valve or electrical disconnect location and proper operation.
Confirm that winch inspections and lubrication checks have been completed
Ensuring no one places their hands on the cable while the air tugger is
connected to the power source.
Notifying supervision of any significant incidents, property damage or near
misses with regards to mobile / motorized equipment.
Participating in the task JSEA and ensuring the lift team follows the JSEA as
written. If any changes occur during the lift, ensuring the operation is stopped
and the JSEA is revisited.
The Signal Person is responsible for:
Providing clear signals and being able to recognize hazards and signal the
operator to avoid them (see Attachment 1).
Use STOP WORK AUTHORITY anytime the signal person is questioning the lift
or lift operation, lifting equipment, lifting accessories or work activities around lift
operation.
Participating in the task JSEA and ensuring the lift team follows the JSEA as
written. If any changes occur during the lift, ensuring the operation is stopped
and the JSEA is revisited.
The Personnel Working around Equipment is responsible for:
Use STOP WORK AUTHORITY anytime any employee is questioning the lift or
lift operation or work activities around lift operation.
Knowing of the hazards of working around equipment.
Keeping a safe distance from operating equipment.
Staying out of designated Red Zone.
Obeying all signs, and barricades.
J1.3
Ensuring no one places their hands on the cable while the air tugger is
connected to the power source.
Never getting on or off moving equipment.
Remaining alert and responding as necessary when an equipment warning
device is heard.
Never walking or working below a raised load on equipment.
Participating in the task JSEA and ensuring the lift team follows the JSEA as
written. If any changes occur during the lift, ensuring the operation is stopped
and the JSEA is revisited.
Definitions
Qualified Operator - A person who has received and successfully completed an
appropriate air tugger / winch operators training, authorized by the Moreno Group, LLC
and Subsidiaries to operate the equipment and meets the following physical
qualifications:
Have vision of at least 20/30 Snellen in one eye and 20/50 in the other with or
without glasses, and have no depth perception problems.
Be able to distinguish red, green and yellow, regardless of position of colors, if
color differentiation is required to crane operation.
Have hearing, with or without a hearing aid, adequate for the specific operation.
Have sufficient strength, endurance, agility, coordination and speed of reaction to
meet the demands of equipment operations
Evidence of physical limitations or emotional instability that could render the
operator a hazard to himself or other or which in the opinion of the examiner
could interfere with the operators safe performance, may be cause for
disqualification.
Evidence that an operator is subject to seizures or loss of physical control shall
be reason for disqualification.
Operators should have good depth perception, field of vision, reaction time,
manual dexterity, coordination and should not be prone to dizziness or similar
undesirable characteristics.
Qualified Inspector - A person who has received and successfully completed the
appropriate air tugger / winch maintenance and is designated by the employer.
Qualified Rigger A rigger is anyone who attaches or detaches lifting equipment to
loads or lifting equipment and/or anyone who directs or signals a lift operation. This
person shall have the training and experience and who has successfully completed API
RP 2d rigger training program.
J1.4
J1.6
In those cases where multiply air tuggers / winches are to be used simultaneously, the
manufactures specifications shall be applied to each individual air tugger / winch
involved in the operations.
All connections must be tight and installation made with hoses, cables and/or fittings
that are new or in good condition and rated for the power supplied. Pneumatic
connections shall be secured using both a safety pin and the appropriately sized whip
checks.
Shut off Valve
On all pneumatic powered air tuggers / winches the installation personnel shall ensure
an accessible emergency shut off valve has been installed in the air supply line. The
valve position shall be installed within easy range of the operator and positioned so that
activation can occur quickly or any person in the area of the air tugger / winch can also
activate the valve. In addition to an emergency shut off valve, this valve will provide the
operator a positive way of stopping the air tugger / winch operations in the event of an
emergency or prior to performing any adjusting, servicing, maintenance or maneuvering
of wire rope on the winch drum. Any time the air tugger is left unattended the air tugger
shall be shut down and depressurized. All personnel involved in and/or around the air
tugger operations shall be instructed and shown where this valve is located.
Air Tugger / Winch Controls
The location of controls and their features varies between air tuggers / winches. This is
dependent on application requirements for each individual air tugger / winch. The
operator shall be familiar with location of controls and their features. Operators should
be aware that controls are not always included with electric and hydraulic powered
winches. Due to the differences in each air tugger / winch, users and operators should
not assume that all winches operate the same. Although, there are many similarities,
every air tugger / winch should be reviewed to identify their individual characteristics.
Each air tugger / winch has specific characteristics that the operator must understand
and be familiar with.
For instance Ingersoll Rands winches are operated by applying power to a motor,
which is connected through a drive train to the drum. The direction of the drum rotation
and speed is managed by the controls. Various controls are available with the winches
and are dependent on power source, location to winch and degree of control required.
For air winches, full flow control valves are normally used which are connected directly
to the winch motor. These have a lever, which is actuated forward and back for direction
control. The degree of lever movement controls drum speed.
Safety features for these operations; levers should not be able to engage without going
through another action first, such as pulling up a safety pin or resisting a safety spring.
Pendant controls are typically used on electric winches but are also available on
pneumatic and hydraulic winches. This type of control sends a signal back to a valve or
control panel mounted to the winch. This control allows the operator to be some
distance from the winch. Pendant controls have levers or buttons which control forward
and reverse drum rotation. The use of pendant controls require additional safety
J1.7
considerations, as the operator may not be at the winch to observe drum rotation or wire
rope spooling. Operators must maintain visual contact with the load, drum and wire
rope at all times.
Exhaust
The installation location shall be evaluated for ventilation to ensure exhaust from these
operations does not affect other operations and eliminates personnel from standing in or
around exhaust streams. A muffler should be used to reduce noise level to acceptable
limits. Pipe away the exhaust where possible to prevent oil mist creating a slippery
environment.
On pneumatic powered winches, careful consideration must be given to the exhaust.
Noise. Using piping or tubing to move exhaust away from operator can reduce
this. The addition of a muffler is also recommended to reduce noise level.
Misting. Clean and remove any build-up of oily residue in area.
Natural/Sour Gas For air powered winches that use natural/sour gas as the
power source, pipe away exhaust from winch. Exhaust system shall provide safe
removal or recirculation of gas and meet all applicable federal, state, and local
safety regulations Note: This application is discouraged and must have
Moreno Group LLC and Subsidiaries Managements Approval at the Vice
President level prior to the use of this type of power supply.
Unauthorized Modifications to Air Tugger / Winch
During the installation or during the operations of any air tugger / winch, no
unauthorized modification shall be allowed without the manufactures written approval
prior to the modification being performed.
Air Tugger / Winch Guards and Barricading of Operations
All guards shall be installed to prevent personnel from accidentally contacting any
exposed moving parts associated with the winch drum. Personnel shall ensure the
guards do not interfere with the air tugger / winch wire rope spooling or control
operations. Guarding moving parts of an air tugger / winch from accidental contact with
personnel shall be a prime consideration for the installation and maintaining of guards
on the air tugger / winch. Guards shall be capable of supporting, without permanent
distortion, the weight of a 200 lb person. In addition, guards shall not cause an operator
to work in a non-stable or ergonomically incorrect position.
The travel area through which the air tugger / winch wire rope travels shall be
barricaded with Red Danger Tape to prevent non essential personnel from entering the
area without permission.
Approval Prior to Start of Operations
Upon completion of the installation of the air tugger to its fixed location, a photo shall be
taken and sent to the Facilitys Register Structural Engineer or Designee for approval of
tie down method and location. In those cases that a photo is unable to be taken, a
detailed drawing shall be made and provided to the Facilitys Register Structural
J1.8
Engineer or Designee. The First Line Supervisor will be responsible for providing the
Facilitys Register Structural Engineer or Designee the following information:
In those cases where a picture can be taken the following additional information shall be
provided:
Picture
Weight of load to be lifted
Size and thickness of clips
Amount and locations of clips
Size and locations for welds (especially on the back portion of the air tugger /
winch)
Tie-in details of snatch blocks
In those cases where a picture can not be taken the following shall be provided:
A Sketch showing tugger placement, snatch block placement
Weight of load to be lifted
Size and thickness of clips
Amount and locations of clips
Size and locations for welds (especially on the back portion of the air tugger /
winch)
Tie-in details of snatch blocks
Snatch Block or Sheave Installation
To prevent the improper spooling of the wire rope on the winch drum, a snatch block or
sheave shall be placed 6 to 8 feet in front of the air tugger. In those cases where the air
tugger / winch is being used to perform a vertical lift, the snatch block shall be placed
above air tugger / winch prior to the line being ran through the deck or grading
penetration.
To help prevent individuals from placing their hands on the air tugger / winch line, Red
Danger Barricade tape shall be placed on the snatch block or sheave as streamers to
help remind individuals not to place their hands on the wire rope.
The snatch block is used to help prevent the improper spooling of the drum rope.
Note: There are two (2) exceptions to this rule they are as follows:
Air tugger / winch operations that requires a straight pull in a horizontal direction.
During these operations a snatch block or sheave is not required.
Air tugger / winch operations that will be performing a downward lift and does not
have an appropriate anchor point for a snatch block or sheave above the deck
opening. In this case the First Line Supervisor must ensure the deck opening is
properly sized and runs the full length of the drum.
Ensuring the proper selection and installation of wire rope and sheaves is important to
maintain the safety of these operations. Sheaves and sheave mounting must be
designed and selected in accordance with all applicable standards, codes and
J1.9
regulations. Improper installation of wire rope or sheave can cause uneven spooling and
wire rope damage that could cause a load to drop.
The First Line Supervisor shall ensure wire rope and the rigging accessories are
correctly rated for the application. The following shall be considered when determining
the rating: weight of the load, weight of the rigging and rigging accessories.
Example of Sheave Sizes Wire Rope Diameter Min. Sheave Diameter inch mm inch mm
Inch.
mm.
Inch.
mm.
3/8
5/8
7/8
1
6
9
13
16
18
22
26
4-1/2
6-3/4
9
11-1/4
13-1/2
15-3/4
18
108
162
234
288
324
396
468
Line Supervisor shall ensure the air tugger / winch operations receives a hot work
permit. The hot work permit shall be obtained from the facility owner for the air tugger /
winch operations. The First Line Supervisor is responsible for incorporating all permit
requirements into the air tugger / winch operations.
Pre Use Inspection / Pre Lift Testing
Prior to every shift and prior to the initial start up of any air tugger operations a pre use
inspection of the winch, wire rope and rigging shall be performed. Any deficiencies shall
be noted on the pre use inspection form, the First Line Supervisor Notified and the
deficiencies corrected prior to the air tugger operations beginning. The pre use
inspection shall be documented on the Air Tugger Operations Pre Use Inspection Form.
(see attachment 1)
The intent of an air tugger / winch operations pre use inspection is to ensure all winch
components and attachments are functioning properly and/or properly adjusted. During
this pre use inspection the operator shall perform an operational test by running the air
tugger / winch slowly in each direction with no load and check the operation of each
attachment or option prior to application use.
For loads exceeding eighty percent (80%) of the air tugger capacity, a pre lift test shall
be performed and documented on the Air Tugger / Winch Pre Use Inspection Form.
This test shall consist of the following:
The test load shall not be less than 110% of the rated load nor more than 125%
of the rated load, unless otherwise recommended by the manufacture.
The test load shall be hoisted a vertical distance to assure that the load is
supported by the air tugger(s) / winch(es) and held by the hoist brake(s).
The test load shall be lowered, stopped, and held with the brake(s).
Note: If a lift is to be used with a multiple number of air tuggers / winches, the test shall
be performed with all air tuggers / winches in operations at once. This pre lift test will
help ensure winch anchors and supporting structure are secure and in good condition.
In addition the following shall be observed and checked.
Ensuring air tugger / winch anchors and supporting structures are secure and in good
condition:
Fasteners - Check retainer rings, split pins, cap screws, nuts and other fasteners
on winch, including mounting bolts. Replace if missing or damaged and tighten if
loose.
Foundation or supporting structure - Check for distortion, wear, rigidity and
continued ability to support winch and rated load. Ensure winch is firmly mounted
and that fasteners are in good condition and tight.
Ensuring air tugger / winch supply cables and hoses are in good condition and
connections are tight:
J1.11
Failure of electric cables or their disconnection while power is supplied can result
in electrocution.
Failure of air or hydraulic hoses or their disconnection while pressurized can
result in hazardous situations including the whipping of hoses. To prevent this
potential hoses shall be connected with safety pins installed in crow feet
connects with the appropriately sized whip checks are installed
Keep clear of whipping hoses. Shut off the compressed air or hydraulic pressure
before approaching the whipping hose.
Notify supervisory or maintenance personnel of any malfunction or damage.
Trained and authorized personnel must determine if repairs are required prior to
operating the winch.
Winch should never be operated with damaged wire rope, controls or guards.
Operating an Air Tugger / Winch
The following operating instructions have been adapted in part from American National
(Safety) Standard ASME B30.7 and are intended to avoid unsafe operating practices
which might lead to injury or property damage. The four most important aspects of
winch operation are:
Follow all safety instructions when operating winch.
Allow only people trained in safety and operation of this winch to operate this
equipment. See Training section of this procedure.
Subject each winch to a regular inspection and maintenance program.
Be aware of winch capacity and weight of load at all times. Ensure load does not
exceed winch, wire rope and rigging ratings.
CAUTION
J1.12
Air tugger / winch operations shall be shut down when winds exceed 25 miles per
hour. No loads shall be lift suspended for any period of time.
If during the lift a load must be held suspended, the following shall be followed:
o Operator shall not leave the controls
o If the load must remain suspended for a considerable time a pawl or other
equivalent means, rather the brake alone shall be used to hold the load.
Erratic control valve operation (can cause a sudden jerk on load which could
create an overload condition).
Removing all obstacle such as buildings, support members, another load, etc
from the path to prevent the load from banging or hanging up on the obstacle.
Should the obstacle be unable to be moved, a different plan and site evaluation
shall be performed.
When multi-parting the load line, the two sheaves come together (also called
Two-Blocking).
During onshore operations, power lines, telephone lines and electrical cables.
During pulling (dragging) operations:
Watch for obstructions that could cause load to hang up, causing sudden
uncontrolled load shift.
Direct foot and vehicle traffic to ensure they maintain a safe distance from the
load path and load line.
Additional Operating Procedures
When a DO NOT OPERATE sign is placed on the winch, or controls, do not operate
the winch until the sign has been removed by designated personnel.
Ensuring proper communication is established with the signal person. When the
operation does not allow for the operator to maintain visual contact on the lift at all times
(i.e. Blind lift), the JSEA shall identify who is responsible for signaling the operator and
identifies the method of communications between signal person(s) and operator.
Keep hands, clothing, jewelry, etc. away from wire rope, drum and other moving parts.
Ensuring the operator operates the air tugger / winch with smooth control movements to
prevent jerking or sudden movements of the load.
Ensure the load is not pulled into support structure or winch of the air tugger
Ensure wire rope hook end is not attached or connected (stowed) to an unmovable
point prior to lift operation.
Immediately stop operation if load does not respond to air tugger / winch control.
J1.13
Ensure brake(s) hold prior to making complete lift by lifting load a short distance and
releasing control.
Ensuring the operator is able to maintain visual contact with the load, drum or wire rope
at all times. During a blind lift, the operator shall ensure an adequate number of signal
persons are identified, appropriately spaced / located, provided appropriate means to
communicate effectively with each other and with the operator. This shall be
documented on the task JSEA.
Ensure all personnel involved in the air tugger / winch operations keep hands and
clothing clear of gaps or spaces on winches, off of wire rope and away from sheaves or
snatch blocks.
Operating in Cold Weather
When operating an air tugger / winch in Cold weather, these operations can present
additional hazards. At very cold temperatures metal can become brittle and the use of
this piece of equipment requires extreme care to ensure that load movements are
smooth and even. The lubricating fluids do not flow as readily during cold temperatures
and every effort to warm all fluids and components before operation needs to occur for
the best performance. The warming of fluids can be accomplished by running the winch
slowly in both directions with no load to initially lubricate components.
In addition to the equipment concerns, operators maybe wearing increased clothing.
Their feel of controls, field of vision and hearing could be impaired due to the increased
clothing. To help minimize these effects the First Line Supervisor shall ensure that
additional personnel and / or signal person are used to maintain a safe operation.
Whenever temperature are below freezing, 32 F (0 C), extreme caution must be
exercised to ensure that no part of product, supporting structure or rigging is shock
loaded or impacted as brittle fracture of steel may result.
Completion of Air Tugger / Winch Operations
At the completion of air tugger / winch operation or when in a non-operational mode the
following actions shall occur:
Remove load from load line. Never maintain a load suspended in the air.
Spool load wire rope back onto winch drum and secure. For load lines over
sheaves or snatch blocks, the wire rope shall be secured in a position that will
avoid a safety hazard in the area.
Turn off/shut off or disconnect power supply.
Secure winch against unauthorized and unwarranted use.
J1.14
Maintain a firm grip on brake lever handle and winch throttle control lever.
Ensure footing is clean, dry and firm.
Maintain a good comfortable posture, do not lean.
Ensure any loose clothing is tucked in or out of the way of the drum.
Ensure the band brake is correctly adjusted which will allow the operator to stop
drum rotation when the brake is fully engaged.
Use Winch Drum Guards which are available and recommended by the
manufacturer for all air tugger / winch installations
Disengaging Clutch
Clutches are used to disengage the drum from the drive train, which allows wire rope to
free spool from the drum. When the drum is in the free spool mode, use of the band
brake to control wire rope payout is required to prevent the loosening of wraps on the
drum. After wire rope is out and connected to load, the operator should engage the
drum and slowly apply tension to wire rope.
On winches with a clutch free spool option, wire rope should spool from drum with
minimal effort. When pulling wire rope from drum in the free spool mode, do not strain
or lose balance and always look where youre going to avoid tripping.
Note: To prevent load control loss, do not disengage the clutch when there is a load on
the air tugger / winch.
Spooling and Handling of Wire Rope
The most important part of wire rope spooling is attaching wire rope to the drum.
Different methods are used to fasten the wire rope to the drum. The individuals spooling
the wire rope shall refer to the Manufactures Product Information Manuals for the
specific method. Note: Failure to match wire rope diameter with the correct wire rope
anchor hardware can cause wire rope to release from drum and drop the load.
Prior to the staring the spooling operations the individual performing this installation
shall ensure all non-essential individuals are kept away from this operations. This shall
be accomplished by barricading the area with Red Barricade Tape around this
operation. Note: Spooling of an air tugger / winch shall not occur offshore unless
determined as an emergency situation by the Offshore Operations Manager.
The individuals spooling the wire rope shall ensure the anchor pocket guard is installed
when provided with the winch. This individual shall check to ensure the wire rope length
is sufficient for the task meaning the length for the entire range of movement specified
for the application, with no less than three (3) full wraps of rope on the drum at all times,
does not exceed the top layer diameter and is approved for the application. At no time
shall anyone be allowed to add additional wire rope to the established length to extend
the length of the air tugger / winch wire rope. All ends of the air tugger / winch wire rope
will be required to have a manufactured eye.
J1.16
Only factory approved hardware shall be used to attach wire rope to drum. When
initially spooling wire rope onto the winch drum make certain that it bends in the same
direction. The proper method of spooling an air tugger / winch is to re-reel from the top
of one reel to the top of another, or from the bottom of one reel to the bottom of another.
It is also necessary to apply a tensioning load to the wire rope to achieve good spooling.
J1.17
Too long a wire rope could exceed the drums spooling capacity, causing the wire
rope to ride over the drum flange resulting in the load dropping, severe damage,
wire rope crushing or complete winch failure.
It is good practice to check the wire rope length whenever the structure is changed, wire
rope is changed or reeving altered. To be certain that wire rope spools evenly on drum
use a spooling device to keep tension on wire rope, approximately 10% of the working
load is recommended. Maintain a fleet angle between the lead sheave and winch of no
more then 1-1/2. A 2 fleet angle is allowable with grooved drums. Exceeding the
specified fleet angle can cause excessive friction, leading to heat build up or sparks.
The lead sheave must be on a center line with the drum, and for every inch (25 mm) of
drum length, be at least 1.6 ft (0.5 m) from the drum. See the diagram below:
J1.18
A. Sheave Flange and Wire Rope Wear; B. Wire Rope Wear; C. Wire Rope Wound too
tightly compressed; D. Uneven Spooling Bunched Wire Rope; E. or; F. When the Fleet
Angle is too small the Result is Poor Winding.
The spooling area shall be clean and free of debris and care shall be taken to ensure
that the wire rope is clean and properly lubricated as it is spooled onto drum. The Wire
rope shall not be allowed to drag or touch the ground during spooling. Prior to the
spooling of the wire rope, an inspection shall be performed of the wire rope and
carefully as the wire rope is being spooled onto drum. The individual installing the wire
rope shall watch for broken or loose strands or other signs of damage or unserviceable
wire rope.
Note: Use of wire rope sizes other than recommended will greatly decrease the life of
the wire rope.
CAUTION
J1.19
Upon completion of spooling and prior to final installation, the individual spooling the
wire rope shall secure the rope to drum. The securing of the wire rope will prevent wire
rope from loosening on the drum.
Grooved drums are designed with the correct groove pitch and depth for one diameter
of wire rope. To determine the proper wire rope size the individual spooling the air
tugger / winch shall refer to the Manufactures Product Information Manuals. Should the
wire rope size and grooved drum do not match, the individual spooling the air tugger /
winch shall notify his First Line Supervisor immediately so either the drum or wire rope
can be replace with the correct size. Remember the use of the wrong diameter wire
rope on a grooved drum will cause improper spooling of the first layer and it will also
cause excessive wear, damage, erratic operation and shortened life of the wire rope.
Winches without grooved drums are designed for a range of wire rope sizes. The
individual spooling the air tugger / winch shall refer to the Manufactures Product
Information Manuals for the specific range. The use of a wire rope with a larger
diameter than specified will result in decreased life of the wire rope and can cause
damage to the internal wire rope strands, which cannot be seen with a visual inspection.
The diagram below illustrates the correct manner to spool wire rope onto the air tugger /
winch drum.
J1.20
J1.21
Attachment 1
J1.22
Customer:
Supervisor:
Job Location:
Operator:
Job #:
Application:
Pull or Dragging
YES
YES
NO
NO
LBS
KG
Metric Tons
Wire Rope
Diameter:
inch
mm
Tagged Capacity
YES
NO
YES
NO
CFM
YES
NO
YES
NO
Certified Grating Hook / Come-A-Long / Cadillac to keep Wire Rope properly aligned
Shut off Valve at air tugger
Barricades installed around tugger operation area
Gear Brake
Communication Method:
Lift Preparations:
Function Test Complete?
YES
NO
tugger capacity)
For Function Test to be valid, all tuggers involved must be operated simultaneously & all brakes tested.
Tugger Air Demands Total:
Total Weight of Load:
lbs
lbs
FOR MULTIPLE TUGGER/VERTICAL LIFTS, THIS CHECKLIST AND JSEA + JOB PLAN MUST BE FAXED
TO MANAGER FOR APPROVAL AND SIGNOFF
Manager Approval:
Supervisor on Site:
Barricading Procedure
Page 1 of 3
Original: 01/01/2004
Revised: 01/01/2008
Barricading Procedure
Purpose
To provide minimum safe work practices for the set-up and maintenance of
barricades that restrict entry and/or provide warning for areas that involve hazardous
activities, unsafe conditions, or unusual circumstances.
Scope
The scope of this procedure is to address the various situations, which require the
use of barricades and the types of barricades, which should be utilized.
Responsibilities
The Facility Manager or Offshore Manager or Designee is responsible for:
Provide resources to fully implement this procedure.
The First Line Supervisor / Offshore Superintendent is responsible for:
Understanding and complying with the requirements of this procedure.
Ensuring that employees comply with the requirements of this procedure.
Evaluating work areas and ensuring that situations, which require barricades,
have been barricaded as per this procedure.
Authorizing employees to enter barricaded area to perform assigned work.
Authorizing employees to remove barricade once hazard has been
eliminated.
The Safety, Health and Environmental Department is responsible for:
Evaluating Program to ensure compliance
The Employee is responsible for:
Understanding and complying with the requirements of this procedure.
Communicating to supervisors any suggestions or concerns related to this
procedure
Stopping unauthorized employees from entering inside a barricaded area..
J2.1
Definitions
Caution Yellow for situations, which may cause minor incident. Signs will be
posted on the barricade to identify the specific hazards and requirements, which
shall be taken inside the barricaded area. Employees shall exercise caution prior to
entering inside a yellow barricade.
Danger Red for hazards which are immediately or potentially life threatening or
can cause serious injury. Only authorized employees shall enter into areas, which
have been barricaded with Danger Red. Signs will be posted on the barricade to
identify the specific hazards and requirements, which shall be taken inside the
barricaded area.
Magenta or Purple or Black on a Yellow background Signage that identifies areas
where there is potential for radiation exposure. Only designated personnel are
allowed inside radiation areas. Moreno Group LLC and Subsidiaries personnel shall
not enter a radiation area at any time unless the crew is not performing any X-raying
and when authorized by the X-ray crew to enter the regulated area.
Protective Barricade - Provides a physical barrier withstanding 200 pounds of
pushing force to protect personnel from hazards such as floor openings or
excavations. Protective barricades shall consist of a toprail, midrail and toeboards.
Anytime wire rope is used, it shall have a diameter of at least 3/8 inch and barricade
should be covered with high visibility orange mesh fencing. If fencing is not
available, red danger flagging needs to be placed at 6 feet intervals on toprail of
barricade to ensure visibility.
Warning Barricade - Erected to call attention to specific hazards, but provides no
physical protection from the hazard.
Requirements
Moreno Group LLC and Subsidiaries will require the use of barricades wherever
necessary for the physical protection of people or property.
The following is a list of activities, which require the use of protective barricades:
Open holes or missing handrails that pose the threat of a fall to a lower level.
Excavations / Trenches
The following is a list of activities, which require the use of Danger Red Color
Coded warning barricades:
Areas underneath construction activities where there is potential for falling
objects.
Areas with temporary wiring operating at more than 600 volts.
Work areas for electrical equipment with exposed, energized parts.
J2.2
Page 1 of 20
Original: 01/01/2001
Revised: 3/16/2010
J3.1
The First Line Supervisor / Offshore Superintendent in charge of the space and
/ or work is responsible for:
Implementing the program in their areas and monitoring compliance.
Assuring that entrants, attendants, gas testing and rescue personnel have
completed the appropriate training.
Obtaining and / or issuing the necessary permits and serve as the Entry
Supervisor.
Verifying that equipment preparation and isolation methods have been
completed (including the placement of tags and / or locks as required) and are
sufficient to protect personnel and equipment.
Perform Confined Space Pre-entry Checklist and Hazard Assessment. (See
Attachment 1)
Performing, or having a qualified gas tester perform, the pre-entry and followup atmospheric monitoring for oxygen, flammable and toxic atmospheres.
Complete Confined Space Entry Permit. (See Attachment 2)
Instructing personnel on the proper methods and safeguards required to
perform the job safely.
Develop Rescue Plan for Entry. (See Attachment 1)
Compliance with pre-set conditions on the permit.
Alerting all affected personnel to changes in area conditions which could
adversely affect personnel or equipment involved.
Leaving the jobsite in a safe, clean condition.
Informing the appropriate personnel when the work has been completed, by
returning and / or signing "off" on the permits (including the removal of any
tags and / or locks used to isolate the equipment).
The Safety, Health and Environmental Department is responsible for:
Maintaining a master list or description of permit and non-permit required
confined spaces at the facility / site.
Assisting Moreno Group LLC and Subsidiaries managers and
supervisors/superintendents with the confined space hazard analysis and the
development of entry and emergency procedures.
Procurement, maintenance and calibration of gas testing equipment.
J3.2
The Attendant may leave his / her workstation only long enough to
summon rescue or emergency services.
J3.4
J3. 5
J3. 7
Monitors activities inside and outside the space to determine if it is safe for entrants
to remain in the space and orders the authorized entrants to evacuate the permit
space immediately under any of the following conditions:
Attendant detects a prohibited condition
Attendant detects the behavioral effects of hazard exposure in an authorized
entrant.
Attendant detects a situation outside the space that could endanger the
authorized entrant.
Attendant cannot effectively and safely perform all the duties required.
Summon rescue and other emergency services as soon as the attendant determines
that authorized entrants may need assistance to escape from permit space.
Take the following actions when unauthorized persons approach or enter a permit
space while entry is underway:
Warn the unauthorized persons that they must stay away from the permit space.
Advise the unauthorized persons that they must exit immediately if they have
entered the permit space
Inform the authorized entrants and the entry supervisor if unauthorized
persons have entered the permitted space.
Perform non-entry rescues as specified within entry SH&E Meeting.
Preventing any unauthorized personnel from attempting a rescue.
Perform no duties that might interfere with the attendants primary duty to monitor and
protect the authorized entrants.
Maintains any Material Safety Data Sheets (MSDS) of chemicals present or
potentially present within confined space.
Duties of Entry Supervisors
The entry supervisor shall be trained and understand the following duties:
Knows the hazards that may be faced during entry, including information on the
mode, signs or symptoms, and consequences of the exposure;
Conducts a Pre-Entry Hazard Assessment of the space to be entered;
Verifies, by checking that the appropriate entries have been made on the permit, that
all tests specified by the permit have been conducted and that all procedures and
J3.8
equipment specified by the permit are in place before endorsing the permit and
allowing entry to begin;
Terminates the entry and cancels the confined space permit if the following happens:
The entry operations covered by the entry permit have been completed; or
A condition that is not allowed under the entry permit arises in or near the
permit space.
Verifies that rescue services are available and that the means for summoning them
are operable;
Removes unauthorized individuals who enter or who attempt to enter the permit
space during entry operations; and
Determines, whenever responsibility for a permit space entry operation is transferred
and at intervals dictated by the hazards and operations performed within the space
that entry operations remain consistent with terms of the entry permit and that
acceptable entry conditions are maintained.
Requirements
A master list of confined spaces at the each location shall be maintained at each
Moreno Group LLC and Subsidiaries facility. Confined Spaces have either been
classified as Permit Required or Non-Permit Required Spaces. All supervisors
should be familiar with this list and consult it to see if a permit is required before
allowing anyone to enter any confined space.
Additions or deletions from the facilitys list of Confined Spaces must be approved by
the Facility / Site Manager and the Safety, Health and Environmental Manager.
Supervision should be alert to the possibility that a confined space may exist or may
be introduced to the facility / site at a later date and that should be added to the list.
Warning signs must be posted at the entrance of confined spaces that may not be
recognized as a confined space.
Anytime multi employers are involved within a confined space a meeting shall occur
to coordinate the entry operation and to determine which permit system will be
followed.
Permit System
Trained Supervision, Safety, Health & Environmental Department or Yard Forman
may only perform atmosphere testing and issuing of Confined Space Entry Permits
(see Pre-Entry Checklist and Hazard Assessment, Attachment 1 and Attachment 2).
The supervisor of personnel performing work inside the space is the recipient of the
permit.
J3. 9
The permitting system shall allow the entry supervisor to evaluate the confined space
to ensure it has been properly prepared for entry. The space shall be blinded at each
inlet and outlet and/ or disconnected, lockout and tagout, cleaned (i.e. purging,
inerting, flushing, steaming, etc.) and properly ventilated.
Note: A double block and bleed shall not be substitute for blinding or disconnecting of
inlets or outlets of the space. Although, double block and bleeds can be used in
conjunction with blinding and disconnecting of inlets or outlets.
The entry supervisor shall barricade the immediate area around the confined space
to protect the space from unauthorized personnel, vehicles, etc. This will help protect
entrants from external hazards being created after the permit has been issued. A
Danger Permit Required Confined Space, Do Not Enter sign shall be placed on
the barricade.
All atmosphere testing and monitoring equipment used in, or to monitor atmospheres
in, confined spaces shall be UL Listed or FM Approved as Intrinsically Safe or
Approved for Use in Hazardous (electrically classified) Locations. Atmosphere
testing and monitoring equipment must have a field calibration check before the initial
use each day. In addition, functional operation checks must be performed before and
after each use. All calibration checks must be recorded and maintained by the
Safety, Health and Environmental Department. Personnel who perform gas testing or
atmospheric monitoring must be trained. Entry attendant will be responsible for
periodically or continuously monitoring the confined spaces atmosphere
Note: All ventilations systems shall be turned off during atmosphere testing.
All permit required and non-permit required confined spaces must have the
atmosphere tested before they are entered. Entry is not allowed into a confined
space with a "hazardous atmosphere".
Permissible exposures to abnormal atmospheres in Confined Spaces for purposes of
entry into confined spaces - a normal working atmosphere will be defined as one
which contains an oxygen concentration of 19.5% minimum and maximum
concentration of 23.5% and is free of harmful amounts of flammable gases, dusts,
and toxic materials (Less than 10% of the LFL and below the PEL or TLV). Anything
other than this will be considered an abnormal or alien atmosphere. Where normal
atmospheres cannot be achieved, personnel will not be permitted to enter.
Entry personnel must be given the opportunity to witness all calibrations of
atmospheric testing equipment and atmospheric monitoring of the space. When entry
personnel feel conditions within the confined space has changed, they can request
additional monitoring to be performed.
Continuous monitoring of the Confined Space atmosphere shall be performed at all
times during the entry. The Entry Supervisor shall recheck the atmosphere of the
confined space after all breaks.
Before any employee is permitted to enter a Permit Required Confined Space, a
Confined Space Entry Permit must be completed by the Entry Supervisor.
J3.10
The Entry Supervisor will communicate the following to all employees involved with
the confined space:
The conditions of the permit and hazards present within space.
The Material Safety Data Sheets (MSDS) of any chemicals present or
potentially present.
Communication procedures to be used between the authorized entrants and
attendants shall be established during this meeting.
Required Personal Protective Equipment, within confined space.
Additional equipment to be used during entry, rescue equipment, alarm
systems, testing equipment, etc.
Duration of permit.
All employees involved in the confined space must read and sign the permit prior to
the posting of the permit at the entrance to the space.
A trained Attendant must be assigned and stationed at the entrance of all permit
required confined space entry jobs. The authorized attendant shall ensure each
authorized entrants name and time entering and exiting the space is placed on the
back of the permit.
Anytime an authorized attendant will be monitoring more than one space, they shall
have radio communication with the entrants and the spaces shall not be more than
10 feet a part from one another. The attendant may not perform any other duties
other than those of an authorized attendant.
A Confined Space Entry Permit is valid for one (1) shift. A new entry permit must be
filled out, and posted at the main access way and reissued every shift or 12 hours.
The permit is void and must be reissued whenever one of the following occurs:
A condition develops which was not covered by the permit.
Unauthorized entry of the Confined Space.
Facility Evacuation Alarm.
An incident within the confined space or outside the confined space that has
affected the confined space.
The confined space permit shall not be removed until all personnel have signed off
the permit. The Entry Supervisor shall identify any problems encountered during the
entry on the permit and forward the permit to the Safety, Health and Environmental
Department for retention. Some examples of problems encountered during any entry
may include:
J3. 11
Wristlets may be used in lieu of the full body harness, for horizontal entry, if the use
of a full body harness is infeasible or creates a greater hazard and that the use of
wristlets is the safest and most effective alternative.
The other end of the retrieval line must be attached to a mechanical device or fixed
point outside the permit space in such a manner that rescue can begin as soon as
the rescuer becomes aware that rescue is necessary. A mechanical device must be
available to retrieve personnel from vertical type permit spaces more than five (5) feet
deep.
Ventilation
General ventilation should be by exhausting from the confined space and discharging
to the outside.
Ventilation equipment should be placed at the top or bottom of the confined space
based on the risk/nuisance factors to be encountered. For example, if the risk factors
are represented by lighter than air gases such as hydrogen (H2) or natural gas
(methane), the air mover must be near the top of the confined space where these
gases will rise. In all other circumstances, the air mover should be at the bottom of
the confined space.
The inlet for ventilation air must be at a position upwind from the air mover to avoid
short circulating which defeats the purpose of ventilation, and away from diesel
engines, etc., such as welding machines.
A positive means of ventilating the vessel or space must be established and operated
the entire time work is in progress. The accepted practice and the recommended
level for general ventilation is one complete air change every three (3) minutes. In
some cases natural may be sufficient. In other cases it may be necessary to use
fans or air movers. The ventilation system must be arranged so that only clean, fresh
air is drawn into the vessel. Ventilation systems should be bonded to the space or
vessel.
If air operated horns are used to ventilate a space they must exhaust outside the
space, not inside. Air horns may only be operated by clean fresh air. Nitrogen,
oxygen or other gases are hazardous and may not be used.
Whenever welding, cutting, burning or brazing is performed in a confined space, local
exhaust ventilation may be necessary to "capture" contaminants or fumes at the
source (the point of operation) and remove them from the atmosphere within the
confined space. The exhaust air mover must be outside the Confined Space and a
flexible hose/duct connected to it and extending to the point of operation. Hot Work
Permits are required before performing these operations in Confined Spaces. Note:
The LEL during Hot Work shall be and remain at Zero during this type operation.
Specific Requirements
Compressed gas bottles (acetylene, oxygen, argon, nitrogen, air, etc.) must not be
brought into a confined space. Anytime work is suspended, welding leads and
hoses must be removed from the confined space. This is to prevent leakage into the
J3. 13
space, which would compromise the atmosphere, and to reduce the risk of an
explosive release into a small area where its effects would be greatly concentrated.
When painting, welding, burning, applying coatings, or doing anything, which might
generate gases, vapors or fumes, adequate ventilation and respiratory protection
must be used. It should also be noted that coatings may cause a fire hazard.
Pneumatic tools should be used whenever possible to reduce the hazard of electrical
shock and ignition sources. Pneumatic tools may only be operated with air. The use
of nitrogen, oxygen, or other gas is prohibited.
Portable electric tools, lights and equipment operated in areas where there is a
potential for flammable or combustible atmospheres to be present or accumulate
shall be of industrial grade, in good condition and UL listed or FM approved as
Intrinsically Safe or Approved for use in Hazardous (electrically classified) locations.
Portable electric tools, lights and equipment used in Confined Spaces shall be of
industrial grade, in good condition, operated at a maximum of 110 volts AC and
connected to a ground fault circuit interrupter, or be operated at no more than 12
volts DC.
When performing hot-work inside of vessels which contained a flammable or
combustible product, the following steps must be taken with written verification in
addition to all other confined space requirements to ensure vessel is safe for hotwork:
Ensure vessel is properly isolated, locked out and blinded with skillets.
Vessel needs to be cleaned of all hydrocarbons.
Once all hydrocarbons have been removed from the vessel, the vessel needs
to be closed off in preparation for steam cleaning.
A valve should be cracked open to drain liquids produced during the steam
cleaning process.
Steam cleaning equipment needs to be setup and grounded. The purpose of
steaming the vessel is to get the vessel hot enough so the pores of the metal
open up and the potential gases in the metal is released.
The vessel needs to be brought to an inside temperature of 120deg F.
Depending on the size of the vessel, this could take several hours. A
temperature stick or thermal gun will be utilized to verify the internal
temperature has reached 120deg F. The vessel must continue to steam for 2
hours at a temperature of 120deg F.
After steam cleaning has been completed, the equipment needs to be turned
off and removed from the vessel.
The vessel should be opened up and ventilated, then verify LEL with a
portable gas meter by a Confined Space Competent Person.
J3.14
Rescue Services
Emergency notification, response and rescue plans must be made in advance. The
Rescue Plan will be documented on the Pre-Entry Checklist and Hazard Assessment
(See Attachment 1). If special equipment is needed such as, scoop stretches, safety
harnesses, retrieval lines, life lines, self contained breathing equipment, etc., it should
be made ready for immediate use. All rescue equipment shall be inspected by a
competent person prior to each entry. This will be documented on the Pre-Entry
Checklist and Hazard Assessment. If there is a reasonable chance that life
threatening incidents (asphyxiation or severe bleeding) may occur, an onsite rescue
team may be needed.
If the facility / site plans to use an offsite rescue team, facility / site management must
evaluate the capabilities of the response group to assure their response times are
appropriate for the hazards. Agreement with offsite rescue teams should be
documented and updated at least annually.
The rescue team shall be given the opportunity to evaluate the entry site, practice
rescue and decline as appropriate.
The rescue team shall have at least one person with a current First Aid / CPR
certification.
The members of the rescue team shall be provided all training and personal
protective equipment at no cost to them to safely perform a rescue.
Non-Permit Required Confined Spaces
To be classified as a "Non-Permit Required Confined Space" the Confined Space
must not have conditions which are, or could reasonably become, "Immediately
Dangerous to Life or Health" (IDLH). Examples of "Non-Permit Required Spaces"
might include, but not necessarily be limited to:
Pits less than four (4) feet in depth
Heating, ventilating or air conditioning (HVAC) plenums designed to be
entered for servicing
Manholes or large diameter pipe that have very low or no potential for a
hazardous atmosphere to develop.
Non-Permit Required Confined Space work should be conducted as work in regular
work areas. However, personnel should consider if:
There have been changes in the Confined Space since it was determined to
be a "Non-Permit Required Confined Space".
The work planned could cause Confined Space to become "Immediately
Dangerous to Life or Health" (IDLH).
J3. 15
Other work being performed in the area of the "Non-Permit Required Confined
Space" could cause it to become "Immediately Dangerous to Life or Health"
(IDLH).
If any of the above apply, the Non-Permit Required Confined Space should be
treated as a Permit Required Confined Space. If there is any question about the
classification, stop and check with your supervisor.
Pipe Fabrication and Confined Space Classification
The fabrication of pipe or other equipment may create a permit required space at
some point in the fabrication process. If, during the fabrication of equipment, the
confined space becomes difficult to enter or exit or could be subject to a hazardous
environment, the Facility Manager, a Safety, Health, Environmental Department
Representative, Yard Foreman, and the First Line Supervisor will decide if special
precautions and / or a permit is required. If all individuals involved cannot agree, the
space must be classified as Permit Required.
Training
Confined Space Entry training will be performed so that all employees acquire the
understanding, knowledge, and skills necessary for the safe performance of their
assigned duties within the confined space entry process.
Training shall be performed to each affected employee on the following intervals:
Before the employee is first assigned duties under this program;
Before there is a change in assigned duties;
Whenever there is a change in permit space operations that presents a hazard
about which an employee has not previously been trained;
Whenever there is reason to believe either there have been a deviation from
the permit space entry procedures or that there are inadequacies in the
employee's knowledge or use of these procedures.
Training of affected employees shall establish the employee proficiency in their duties
within this program and shall introduce new or revised procedures as necessary.
The employee training shall be certified that the training has been accomplished by
providing the following information within the employees training records:
Employees Name
Signature or initials of the Trainer
Dates of training
J3.16
J3. 17
Attachment 1
J3.18
Date:
Job Name:
Job Number:
No
N/A
Is the entry necessary?
Has the customer informed Moreno Group LLC and Subsidiaries of the
hazards applicable to the Confined Space?
Is there a potential for any of the following conditions to be present?
Oxygen Deficient / Enrichment
Toxic Atmosphere
Engulfment
Corrosive Atmospheres
Electrical
Mechanical
Temperature Extremes
Have Material Safety Data Sheets been obtained from the customer?
Has the area been surveyed for external hazards? (i.e., drifting vapors,
nearby hot work, traffic and vehicular movement, potential ignition sources,
etc.)
Have you reviewed with the customer hazards specific to Moreno Group LLC
and Subsidiaries equipment processes?
Lock Out / Tag Out, Binding and Blanking
Yes
No
N/A
Has the space been isolated from all other systems?
Has all electrical equipment been locked out?
Have disconnects been used where possible?
Has mechanical equipment space been blocked, chocked and/or
disengaged?
Have all the lines in the space that are under pressure been blanked or bled?
Has the space been washed, cleaned or rinsed before entry is made?
J3.18.a.1
1
What are the physical characteristics of any remaining contents in the space?
Solids
Gases
Liquids
Vapors
Semi-Solids
Other
Dusts
Sludges
Yes
No
Atmospheric Testing
Yes
No
N/A
Is the person conducting the testing trained in the proper use of the testing
equipment?
Are the instruments being used for testing properly calibrated? (manufacturer
or field)
Has the Atmosphere in the Confined Space been tested?
Specify person by name:
Position:
Was the oxygen content at least 19.5% and less than 23.5%?
Were there toxins, flammables, oxygen displacing gases / vapors present?
Will the atmosphere in the space be monitored while work is ongoing?
Specify intervals:
Continuously
Periodically
Note: Atmospheric changes can occur due to the work procedures or the product stored.
The atmosphere may be safe on initial entry, but can change very quickly.
Ventilation:
Yes
No
N/A
Has the space been ventilated prior to entry?
Will ventilation be continuous during entry?
Mechanical
Natural Draft
Is the air intake for the ventilation system located in an area that is free of
combustible dusts, vapors / gases and toxic substances?
If the atmosphere was found unacceptable and then ventilated, was it re-tested
and found acceptable prior to entry?
No
N/A
Is specialized clothing required? If so, specify
Level of Protection
A
B
Other
Are special tools required? If so, specify, (i.e., spark proof, explosion proof,
etc.)
J3.18.a.2
No
N/A
Is respiratory protection required?
Specify: Manufacturer:
Air Purifying
Supplied Air
SCBA
Cartridge Type:
Can entrants / rescuers get through the opening with an SCBA on? (If you
dont know, find out prior to beginning the job)
Training
Yes
No
N/A
Have all participants been trained / fit tested in the proper use of the respirator
required for entry?
st
Has at least one person on the team been trained and certified in 1 Aid and
CPR?
Have all participants been trained in Confined Space Procedures?
Entry Supervisor / Competent Person
Entrant
Attendant
Attendant / Rescue
Yes
No
N/A
Will there be an attendant on the outside in constant visual or auditory
communications with the entry team on the inside?
Will the attendant be able to hear and see the entrants at all times?
Has the attendant been trained in Emergency Procedures?
Has an Emergency Rescue Action Plan been completed?
Are safety lines and harnesses in place to assist in removing a person?
Are rescue procedures available to be followed in the event of an emergency?
Are all participants familiar with emergency rescue procedures?
Do all participants know who to notify, and how, in the event of an emergency?
No
N/A
Inspect all screws, bolts, nuts to ensure they are tight and not bent or broken.
Inspect all covers, housings, and guards to ensure free of cracks, dents, or other
damage.
J3.18.a.3
Yes
No
N/A
Inspect crank handle to ensure that it locks positively onto the shaft and be free of
cracks, bends, or any other visible damage.
Inspect connecting hook to ensure there is no damage, breaks, distortion, or have
any sharp edges, burrs,
cracks, worn parts, or corrosion.
Insure the connecting hook works properly. Hook gate must move freely and lock
upon closing. Hook must swivel freely.
Inspect wire rope assembly starting at the hook by bending along the length of the
cable by inspecting closely for cracks, breaks, corrosion, or frayed strands.
Inspect all identification and warning labels ensuring they are legible and securely
attached.
Inspect each system component (support structure, backup fall arrest system, body
support, and connectors.
Inspect the winch locking mechanism, drum, and drum sprocket for damage. The
locking mechanism should move smoothly in and out of the drum sprocket.
Check operation of the winch in high speed and low speed positions. Must crank
up and back down freely.
Inspect the ratchet brake with brake engaged. The drum should be prevented from
releasing cable. The spring must be in place and not damaged.
Inspect for oil in the gearbox by removing plug on top and tilting unit so oil can be
seen through the hole. Then inspect for leaks. Replace with SAE 80 or 90 gear oil if
needed.
Check operation of the handle over the speed brake.
J3.18.a.4
The following standard hand signals will be used in the event audible communications are lost.
Hand Gripping Throat
Thumbs Up
Im OK, I understand
Thumbs Down
No. Negative
J3.18.a.5
Attachment 2
J3.19
J3.19.a.1
Attachment 3
J3.20
J3.20.a.1
J3.20.a.2
Crane Policy
Page: 1 of 36
Original: 01/01/2001
Revised: 09/01/2009
Crane Policy
Purpose
The purpose of this policy is to establish and set guidelines for the safe use of material
handling equipment related to crane operations per 29 CFR 1910.179, 29 CFR 1910.180
and API RP 2d.
Scope
This procedure applies to all Dynamic employees, non-permanent employees
and sub-contract employees who operate, use, inspect, maintain or work around
cranes.
Responsibilities
The Facility Manager / Yard Manager / Offshore Manager or Designee is
responsible for:
Continually communicated to First Line Supervision the employees right to use
STOP WORK AUTHORITY.
Assuring compliance with this procedure.
Evaluating mobile equipment needs for the facility / site, preparing detailed purchase
/ rental specifications and providing sufficient equipment to support the needs of
Dynamic Industries.
Assuring the equipment is operated and maintained in a safe manner and in
accordance with equipment manufacturers recommendations.
Assuring that equipment operators are properly trained and qualified to operate
specific machines.
Ensuring that no modifications or additions are made to equipment without the
manufacturers written approval.
Ensuring that all work group investigations, significant incidents, property damage
reports, and general information regarding mobile / motorized equipment is
communicated to applicable employees.
Informing all Contractors of this procedure during the project meeting and ensure the
Contractor follows the requirements of this procedure.
J4.1
J4.2
J4.3
Qualified Inspector - A person who has received and successfully completed the
appropriate
crane
maintenance
and
is
designated
by
the
employer.
Qualified Rigger A rigger is anyone who attaches or detaches lifting equipment to loads
or lifting equipment and/or anyone who directs or signals a lift operation. This person shall
have the training and experience and who has successfully completed a rigger training
program.
Initial Inspection - An inspection that applies to cranes that are new to the location and are
being placed into service and are being permanently relocated. A qualified inspector shall
conduct this type of inspection. Every initial inspection shall include a load test.
Pre-use Inspection - An inspection that is performed daily by the qualified operator. This
type of inspection shall be conducted prior to beginning each new shift.
Designated Personnel - Only designated personnel shall be permitted to operate a crane
covered by this policy.
Red Zone- Designated area around a crane or equipment that must be clear of all nonessential personal before operation begins.
Requirements
Mobile Cranes
All cranes shall have specifications as to their rating and load capacity for safe operation.
The qualified operator to ensure the safety of the operation shall strictly follow the rating
measurements. The operating rating chart and load chart shall be visible to the operator at
all times. The manufacturers load rating shall not be exceeded unless prior approval is
obtained from the manufacturer. All crawler, truck, or locomotive cranes in use shall meet
the applicable requirements for design, inspection, construction, testing, maintenance and
operation as prescribed in the ANSI B30.5-1968 including all jibs shall having positive stops
to prevent their movement of more that 5 degrees above the straight line of the jib and
boom on conventional type crane booms.
A qualified inspection company under the following conditions shall conduct certified load
tests:
New cranes being placed into service.
Cranes that are being permanently relocated.
Temporary / rental cranes after each rig-up or relocation.
The documentation illustrating the load test procedure and the results shall be maintained
readily available for a period of 3 years at the facility
J4.4
J4.5
Inspection Records
Certification records, which include the date of inspection, the signature of the person who
performed the inspection and the serial number or other identifier of the crane, which was
inspected, shall be made daily. The daily (pre-use) shall be maintained for 1 calendar
quarter (see Attachment 2) and the periodic inspections shall be maintained readily for 3
years.
Inspection Program
The following reflects the requirements of OSHA 1910.179(j) and (m) and constitutes
minimum inspection requirements. Prior to initial use all new and modified cranes must
have an initial inspection to ensure they are in good condition and safe for use.
Inspection procedure for cranes in regular service is divided into two general classifications
based upon the intervals at which inspection should be performed. The intervals are
dependent upon the nature of the critical components of the crane and the degree of their
exposure to wear, deterioration, or malfunction. The two classifications are designated with
respective intervals between inspections as:
Frequent inspection -- Daily to monthly intervals.
Periodic inspection -- 1 to 12 month intervals.
Note: Should either of the above mentioned inspection indicates the need for a
nondestructive type of testing of the crane hook, the use of outside firm to perform the nondestructive testing of Dynamics equipment requires written proof that technicians are
certified to the latest requirements of the Society for Non-Destructive Testing and that their
inspection equipment was calibrated prior to the inspection itself.
Frequent Inspections
The following items must be inspected for defects at daily to monthly intervals or as
specifically indicated. This must include observation during operation for any defects which
might appear between regular inspections. All deficiencies must be carefully examined and
a determination made as to whether they constitute a safety hazard.
All functional operating mechanisms for maladjustment interfering with proper
operation.
Deterioration or leakage in lines, tanks, valves, drain pumps, and other parts of air or
hydraulic systems.
Hooks with deformation or cracks. Visual inspection with a certification record which
includes the date of inspection, the signature of the inspector, and the serial number,
or other identifier, of the hook inspected. Hooks with cracks, or those having more
than 15 percent in excess of normal throat opening or more than 10 degrees twist
from
the
plane
of
the
unbent
hook
must
be
discarded.
Hook safety latch/wire in undamaged and functional.
J4.6
Hoist chains, including end connections, for excessive wear, twists, distorted links
interfering with proper function, or stretch beyond manufacturer's recommendations.
Visual inspections with a certification record which includes the date of inspection,
the signature of the inspector and an identifier of the chain which was inspected
shall also be included.
All functional operating mechanisms for excessive wear of components.
Wire rope reeving for noncompliance with manufacturer's recommendations.
Spreader bars must be checked for mechanical integrity to locate cracks, bends,
deformations, connecting devices, etc. If any deficiencies are found, they need to be
corrected before operation is started. The deficiencies and corrective actions shall
be documented and maintained for 1 calendar quarter at the facility.
Periodic Inspections
Complete inspections of the crane should be performed at one to twelve month intervals,
depending upon its activity, severity of service, environment, or as specifically indicated
below. These inspections must also include the following items. Any deficiencies must be
carefully examined and determination made as to whether they constitute a safety hazard.
Deformed, cracked or corroded members.
Loose bolts or rivets.
Cracked or worn sheaves and drums.
Worn, cracked or distorted parts such as pins, bearings, shafts, gears, rollers,
locking and clamping devices.
Excessive wear on brake system parts, linings, pawls, and ratchets.
Load, wind, and other indicators over there full range, for any significant
inaccuracies.
Gasoline, diesel, electric, or other powerplants for improper performance or
noncompliance with applicable safety requirements.
Excessive wear of chain drive sprockets and excessive chain stretch.
Electrical apparatus, for signs of pitting or any deterioration of controller contacts,
limit switches and pushbutton stations.
Cranes Not in Regular Use must be inspected as follows:
A crane which has been idle for a period of one (1) month or more, but less than six
(6) months, must be given an inspection conforming with all requirements of this
procedure before placing it in service.
J4.7
A crane which has been idle for a period of over six (6) months must be given a
complete inspection conforming with requirements of this procedure before placing it
in service.
Standby cranes must be inspected at least semi-annually in accordance with
requirements of this procedure.
Running Ropes
A thorough inspection of all ropes must be made at least once a month and a certification
record which includes the date of inspection, the signature of the inspector, and an
identifier for the ropes which were inspected must be kept on file where readily available.
Any deterioration, resulting in appreciable loss of original strength must be carefully
observed and determination made as to whether further use of the rope would constitute a
safety hazard. Some of the conditions that could result in an appreciable loss of strength
are the following:
Reduction of rope diameter below nominal diameter due to loss of core support,
internal or external corrosion, or wear of outside wires.
Reductions from nominal diameter of more than 1/64 for diameters to and
including 5/16.
Reductions from nominal diameter of more than 1/32 for diameters 3/8 to and
including .
Reductions from nominal diameter of more than 3/64 for diameters 9/16 to and
including .
Reductions from nominal diameter of more than 1/16 for diameters 7/8 to 1 1/8
inclusive.
Reductions from nominal diameter of more than 3/32 for diameters 1 to 1
inclusive in standing ropes, more than two broken wires in one lay in sections
beyond end connections one more than one broken wire at an end connection.
A number of broken outside wires and the degree of distribution or concentration of
such broken wires.
Worn outside wires.
Corroded or broken wires at end connections.
Corroded, cracked, bent, worn, or improperly applied end connections.
Severe kinking, crushing, cutting, or unstranding.
All rope and choker cables, which have been idle for a period of a month or more due to
shutdown or storage of a crane on which it is installed, must be given a thorough inspection
before it is used. This inspection must be for all types of deterioration and must be
performed by an appointed or authorized person whose approval is required for further use
of the rope. A certification record must be available for inspection, which includes the date
of inspection, the signature of the inspector and an identifier for the rope, which was
inspected.
J4.8
If any deficiencies are found, they need to be corrected before operation is started. The
deficiencies and corrective actions shall be documented and maintained for 1 calendar
quarter at the facility.
Preventive Maintenance Program
A preventive maintenance program based on the crane manufacturer's recommendations
must be established by Maintenance Services. Records of the preventive maintenance
inspections must be kept for the life of the equipment.
Adjustments and repairs on a crane and other lifting equipment must include the following
precautions:
The lifting equipment to be repaired must be run to a location where it will cause the
least interference with other equipment and operations in the area.
Where other lifting devices or equipment are in operation on the same runway, rail
stops or other suitable means must be provided to prevent interference with the idle
crane.
Safe Operating Practices for Mobile Cranes
Cranes are carefully designed, tested and manufactured. When used properly by qualified
operators, they will give safe, reliable service.
Because cranes have the ability to lift heavy loads to great heights, they also have a
potential for accidents if safe operating practices are not followed. This section will help
you prevent accidents which could result in injury, death or property damage.
General safe practices for working on machinery must be followed as well as the safe
operating practices recommended here.
Safety devices installed on any crane shall not be over ridden. Should a safety device
need to be over ridden to perform a lift safely, this lift must be approved by Facility
Management. A specific JSEA shall be developed for this lift which shall include a spotter.
First line Supervision and a SH&E Representative shall be present during this lift.
Safety device shall not be over ridden for any lift involving the lifting of personnel.
Each crane shall have a dry chemical fire extinguisher located in the crane cab.
Cranes swing radius shall be barricaded to prevent employees and equipment access into
the area of the swing radius.
No loading or unloading of equipment and/or material is allowed after normal working hours
without Management's approval.
J4.9
Whenever internal combustion engine exhausts in enclosed spaces, tests shall be made
and recorded to see that employees are not exposed to unsafe concentrations of toxic
gases or oxygen deficient atmospheres.
Planning the Job
Most accidents can be avoided by careful job planning. The person in charge must have a
clear understanding of the work to be done, consider all dangers at the jobsite, develop a
plan to do the job safely (i.e. Job Safety and Environmental Analysis), and then explain the
plan to all involved in the crane operation. Factors such as these should be considered:
What crewmembers are needed and what responsibilities will they be given?
What is the weight of the load to be lifted, the lift radius, boom angle and the rated
capacity of the crane?
How will the signalman communicate with the operator?
What equipment is required to do the job safely?
How can the equipment be safely transported to the jobsite?
Is the crane safe to mount and dismount using the handholds and steps provided by
the crane manufacturers?
Are there power lines or structures, which must be moved or avoided?
How will loads be rigged?
What special safety precautions will be taken if the crane must travel with a
suspended load or if more than one crane is needed to lift a load?
Are unusual weather conditions such as wind or extreme cold weather expected?
What steps will be taken to keep unnecessary people and equipment safely away
from the work area? Is barricade tape needed to identify hazards and the work area?
How can cranes be positioned to use the shortest boom and radius possible?
Note: A crane lift plan shall be utilized for lifts greater than 50% of the crane's rated
capacity, if two are more cranes are used or if other conditions warrant a critical lift.
Operating Precautions
Only qualified and properly designated operators shall operate the machine. The operator
needs to know the location and purpose of all controls, instruments, indicator lights and
labels. An operator also needs to comprehend load chart notes and accurately calculate a
machines load handling capacity.
J4.10
General Operation
The engine should not be started if the main, auxiliary hoist and/or swing are released.
Always warm up the engine and hydraulic system before attempting to operate the
machine. Watch all instrument readings, if readings are not correct stop the engine and
find cause.
Avoid sudden applications of all controls, particularly at start and end of each operation.
Propel with engine rpms around medium position.
Avoid Power Lines
Always survey the work area to determine whether there are power lines in the area.
OSHA regulations require at least ten (10) feet clearance from lines carrying up to 50,000
volts. Greater clearances are required for lines with higher voltages. All overhead power
lines shall be considered energized unless verified and indicated by the utility company
owning the line that it has been de-energized and grounded. Some states require that you
stay as far as possible from power lines and never violate minimum clearances. In the
State of Louisiana, we must notify the owner of the electrical line within 48 hours of our
operation. The power company must determine if line will be deenergized or other means
will be put in place.
During Operation
Foot pedal brake locks are furnished on some cranes to allow the operator to rest
his legs when suspending the load for short periods of time. Keep your feet on the
pedals while foot pedal brake locks are in use. Brakes may cool, if not leaked down
properly, allowing the load to fall.
When you operate the crane, do not let another person on the machine.
J4.11
When you get on or off the crane, use handrails and steps. Start the engine only in a
well-ventilated area.
Before you move the boom, swing, travel or hoist ensure all persons are away from
the load area.
Trying to repair or adjust equipment with a suspended hook or load or with the boom
raised could release machinery and let it move unexpectedly. Always lower the load
to the ground and the boom onto proper cribbing before doing maintenance or repair
work.
Leaving a machine unattended can be very dangerous. Never leave the operators
cab with the engine running or with the load suspended. Before leaving his or hers
seat, the operator shall take the following steps to prevent his machine from moving:
Lower the load to the ground.
Lower the boom when necessary.
Set the swing brake or lock.
Set all drum pawls.
Set parking brakes and shut off engine.
Suspended Loads
An Operator shall avoid swinging a load over personnel and not allow them to work or walk
under any part of machine or load.
A warning signal shall be sounded when approaching personnel.
Apply hoist brake, drum pawls and swing brake if the engine stalls during operation.
Pick and Carry
Load ratings for cranes are based on the machine being stationary and level. Traveling a
crane with a suspended load or with the boom erected involves special hazards, including
the possibility of side loading or tipping over.
Because of the many variables involved in pick and carry operations, the user must
evaluate conditions and take precautions such as these:
Check the load chart and notes for limitations.
Position the boom in line with the direction of travel.
Reduce the maximum load while traveling to reflect operating conditions. The safe
load will vary depending on speed, crane, terrain and other conditions.
Travel slowly and avoid sudden stops and starts.
J4.12
Avoid backing away from the load. This could increase the radius and cause the
machine to tip over.
Use tag lines to keep loads under control.
Keep the load close to the ground while using the shortest boom possible.
Move Crane Safely
Before you move a crawler or wagon crane; find out which way to move propel levers
for the direction you want to go. If the propel motors are in front of the cab, pull the
propel levers back to move forward.
When traveling:
Do not travel near the edge of a ditch, gully or excavation.
Travel carefully where room is limited, over rough ground and on slopes.
Use a signal person.
Know your machine height, width and weight.
Know bridge load limits and do not exceed them.
Be sure of tail swing clearance in a narrow spot.
Control travel speed for safely moving and ensure ball or block is secure.
Park Safely
Before the operator leaves the cab ensure the following is conducted:
Lower the load to ground and apply the brakes.
Put control levers in neutral position.
Shut off engine.
Never park on an incline with out carefully blocking the machine to prevent
movement.
Do not leave it where there is a chance of a bank caving in or a low spot where rains
may wash out the footing.
Take the engine key and the cab door key with you.
J4.13
Always dismount facing the crane using handholds and step provided by your
employer or crane manufacturer.
Offshore Cranes
A qualified operator (API RP 2d qualified) shall conduct all offshore crane operations. All
crane operations shall be conducted in a safe manner. At a minimum this shall include the
following:
The operator will perform a Pre-Use Inspection.
The crane operator will become familiar with the load in respect to its weight and
configuration including all special rigging used to lift it prior to making the lift.
When determining if the fast line can be used for a lift, identify from the load chart
the dynamic lifting capacity of the crane (fast line) at the lowest proposed lift angle or
longest radius. If the lift is within 10% of this dynamic lifting capacity the fast line
shall not be used.
The crane shall not be overloaded.
Loads shall not be moved over personnel.
All personnel involved in the lifting operations shall develop and review a Job Safety
and Environmental Analysis to clearly communicate the lifting operation. All
personnel must be clear of the load before it is lifted or moved.
Crane lifting operations may not begin until the crane operator has designated one
qualified signal person for all areas where the crane operator's vision is, or will be,
obstructed during any part of the lift. The crane operator and the signal person(s)
must maintain direct communication with each other throughout their portion of the
lift either visually or by radio. Examples of situations requiring two signal persons
would include lifts from one deck to another deck (if the signal person from one deck
remained on that deck) and lifts to and from boats.
The crane operator shall respond to signals only from the designated signal
person(s), but shall obey any "STOP" signal from anyone whenever it is given. If a
stop signal is given, crane operations shall cease until the appropriate designated
signal person verifies that it is safe to resume operations. When it is safe to resume
operations, the appropriate designated signal person shall communicate that fact to
the crane operator.
When helicopter approaches a facility, the crane boom shall be swung away from
the heliport, the swing lock shall be engaged, and the crane operator shall step out
of the cab of the crane. Pilots have been instructed not to land if anyone is in a
crane cab. If a lift is in progress, the lift should be completed before the crane is
secured.
J4.14
Due to potential safety hazards, the crane boom shall be properly cradled under the
following conditions: severe weather, high winds, and periods of infrequent use
(defined as: several hours, not days) especially at night.
On lifting, the load hook shall be positioned directly over the load to avoid a side
thrust on the boom and to prevent the load from swinging. The swing brake should
be unlocked at this time to allow the boom to track the load.
The crane shall not be used in a manner that might result in shock loading (for
example, pulling up grating that is still welded to the platform).
Safety devices installed on any crane shall not be over ridden. Should a safety
device need to be over ridden to perform a lift safely, this lift must be approved by
Offshore Management. A specific JSEA shall be developed for this lift which shall
include a spotter. First line Supervision and a SH&E Representative shall be
present during this lift.
Safety device shall not be over ridden for any lift involving the lifting of personnel.
Personnel Transfer
A personnel basket will be used for all offshore transfers between a facility and a
boat whenever the crane is used to make the transfer.
Only properly designed workbaskets shall be used as work platforms or
workstations. Personnel baskets are not designed for this purpose and shall not be
used as such.
Crane hooks used to lift personnel baskets will have a positive locking device (not a
spring loaded flap or clip)
All shackles incorporated in a Personnel Basket lifting configuration will be tight and
wire locked.
Personnel lifts to and from a motor vessel shall be swung over water whenever
possible.
All personnel being transferred over water must wear an approved life preserver that
is properly donned.
A maximum of four (4) personnel are permitted to ride in the personnel basket at a
time.
Personnel riding on the personnel basket shall ride on the outside of the basket,
facing inward, with their arms locked around the netting.
Personnel baskets will be equipped with tag lines free of knots.
J4.15
Cargo other than personal hand luggage and small supplies and equipment will not
be transferred with the personnel basket. Cargo must not overhang the edge of the
personnel basket.
All personnel baskets will have a safety "shock" load strap.
Cranes shall not be used to raise or lower personnel into or out of tanks or other
production vessels. Only properly designed personnel hoisting equipment shall be
used for this purpose.
Personnel are not allowed to ride on the following: any load, slings, cables,
"headache" ball (connected to the whip line or fast line), nor the load block.
All personnel lifts shall be under power control both up and down.
Offshore Operator Training Requirements
New Hire
All employees being hired to operate an offshore crane must contain and present a
current certification for the type of crane they are being hired to operate.
Upon successful completion of Dynamic Industries, Inc. New Hire Process (i.e. medical
surveillance, etc.) and our New Employee Hire Process and New Employee Orientation /
SH&E Training, this new operator must obtain a new API RP 2d offshore pedestal crane
certificate from Dynamic Industries, Inc. This training / certification shall be performed by a
recognized Third Party Training Company. The training shall meet all requirements of the
last edition of API RP 2d and shall be performed at a minimum every 4 years.
Current Employees
All employees who are or being promoted to an offshore crane operator status shall be
medically cleared prior to receiving their API RP 2d training / certificate. This training /
certification shall be performed by a recognized Third Party Training Company. The
training shall meet all requirements of the last edition of API RP 2d.
Note: If the operator does not maintain and present documentation of a current operator
certification, local Management and the SH&E Department will need to discuss an
apprenticeship program for this operator prior to allowing them to operate for Dynamic
Industries, Inc..
Overhead Cranes
Before operating the crane, the crane operator should carefully read and study the
operation manual supplied by the Crane manufacturer and note any special instructions not
given previously by the proper instructor or supervisor.
With the mainline switch open (power off) the crane operator should operate each master
switch or push button in both directions so as to get the feel of each device and also to
J4.16
determine that they do not bind or stick in any position. If any of them do, before doing
anything else, the operator should report the condition to the proper supervisor.
Operator Responsibility
The crane operator should be held directly responsible for the safe operation of the crane.
Whenever there is any doubts as to safety, the crane operator should stop the crane and
refuse to handle loads until:
Safety has been assured.
The operator shall not permit anyone to ride on the hook or the load.
Learning the Controls
Having observed the feel of the controllers, the crane operator is now ready to try the crane
with power applied.
After checking to be sure no one is on or near the crane, close the crane disconnecting
means and press the ON or RESET button so that the power is ON.
Try the hoisting motion first. The hook should be in an intermediate position. Move the
master or push button slowly in the up direction or press the UP button in the pendant in
J4.17
the same manner. The resultant movement should correspond with master switch or push
button markings for all motions. Observe the speed increase in relation to the steps in the
controller. Try to feel the steps in a pendant-type controller. Move the hook to a position
near the upper hook position and slowly inch the hook into the upper limit stop position.
The limit switch should cause the hoisting motion to stop at the upper limit of travel. If any
malfunction of either the hoist brake or the limit switch is suspected, this condition should
be reported to the supervisor before proceeding. The hoist limit switch should never be
used as an operating control for stopping the load. It is to be considered as an emergency
limit switch only.
Repeat this procedure with the trolley controller. If the trolley is not equipped with a brake,
note how it can be stopped by momentarily operating the control in the first point of the
reverse direction. This is known as plugging. Next try the bridge motion, first making
sure that the first movement is in the direction the bridge is free to travel. Check the
stopping of the bridge by means of the brake and by plugging.
Good operators should always remember and follow four simple rules:
Start all motions slowly, by moving the controller handle or push button step by step
until the fastest safe speed is reached.
Stop slowly, by bringing the master switch or push button to the off position step by
step so as to minimize swinging of the load and unnecessary wear of the brakes.
Learn to judge the drift of each motion of the crane after power is removed. Proper
use of this drift will facilitate spotting of the load and minimize wear of crane
components.
Handle the load in a safe manner with the area free of personnel and other
obstructions.
Handling the Bridge Travel Motion
Before using the trolley or bridge of the crane, the operator should be sure the hook is high
enough to clear any obstruction. Before a load is handled by the crane, the bridge should
be brought in position so that it is directly over the load. Otherwise it will be impossible to
spot the trolley and hoist hook over the load.
In addition to other operating controls, the bridge has a brake, usually operated by a foot
pedal in the cab or an electric brake where push button floor control is used. The purpose
of this brake is to permit stopping the bridge exactly where desired. After the operator has
learned the distance that the bridge travels after power is removed, the operator should be
able to judge distances so that the need to use the bridge brake will be greatly reduced.
On floor-controlled cranes, the electric brake will set automatically when the push button is
released.
Handling the Trolley Travel Motion
Before a load is handled, the hoist should be brought directly over the load that is to be
handled. When the slack is taken out of the slings, if the hoist is not directly over the load,
J4.18
bring it directly over the load before hoisting is continued. Failure to center the hoist over
the load may cause the load to swing upon lifting.
If the trolley is equipped with a brake, follow the instructions given for controlling the bridge.
If the trolley is not equipped with a brake, this motion may require more skillful handling
than any other motion of the crane. As the operator becomes familiar with the crane, he
can gauge the amount of drift and allow for it. This will eliminate the necessity of quickly
reversing power to the trolley motor to bring the trolley to a stop.
Always start the trolley motion slowly and reduce the trolley speed gradually. For very
slight trolley movements, follow the practice of inching as described in Handling the
Bridge Travel Motion.
Handling the Hoist Motion
After the hook has been brought over the load, lower it until the load can be attached to the
hook. As the hook approaches this level, reduce the speed so that the lowering can be
stopped smoothly and quickly.
If load slings are used to handle the load, the slings should be fully seated in the saddle of
the hook. With the hook latch closed (if equipped with hook latch), the hook should be
started upward slowly until all slack has been taken out of the slings. Then the load should
be lifted slowly until it is clear and it has been determined that the load is properly balanced
and the slings properly placed. The hoisting speed may then be increased and maintained
until the load is clear of all obstructions or if a hitcher gives the signal to stop.
Housekeeping
Good housekeeping should be maintained at all times. The crane operator should keep the
crane cab and access or pendent controls clear and clean. Do not permit loose objects
such as tools, bolts, boards, etc. around the cab or on the crane because they represent a
safety hazard.
Inspection
Test all controls on the crane at the beginning of each shift. Be sure the limit switchers,
brakes, ropes, hooks and other protective devices are in good working order. Check crane
for such things as proper functioning of all controls, and check for loose or damaged parts.
Weekly the hook of the overhead crane shall be inspected (see Attachment 4 or Hazard
Assessment Checklist (Shop)).
Note: Should the above mentioned inspection indicate the need for a nondestructive type of
testing of the crane hook. The use of outside firm to perform the non-destructive testing of
Dynamics equipment requires written proof that technicians are certified to the latest
requirements of the Society for Non-Destructive Testing and that their inspection equipment
was calibrated prior to the inspection itself.
J4.19
Whenever the operator finds anything wrong or apparently wrong, the problem should be
reported immediately to the proper supervisor. See Sling section for inspections of wire
rope and slings.
Signals
Standard crane signals should be accepted from only ONE authorized person except
where it is apparent that not doing so would result in an accident.
Obey a STOP signal at all times, no matter who gives it.
Loads should not be moved unless the standard crane signals are clearly given, seen and
understood.
Unusual signals are seldom required, but if used they should be thoroughly understood by
the crane operator and authorized person giving the signal.
During any lift where the operators vision is blocked, radio communication shall be used to
relay signals.
Stay Alert
The crane operator should keep hands on the handles of the controller or master switches,
which control the motions in operation so stops can be made quickly in case of an
emergency. Stand up, when necessary to improve vision, when making a lift or when
moving a load in any direction. Be especially alert for any unusual sounds or warnings.
Danger may be present that the crane operator cannot see.
Operating Precautions
One measure of a good crane operator is the smoothness of the crane operation. Jumpy
and jerky operation, flying starts, quick reversals and sudden stops are the trademarks of
a poor operator. The good operator should know and follow these proven suggestions for
safe, efficient crane handling:
Crane controls should be moved smoothly and gradually to avoid abrupt, jerky
movements of the load. Slack must be removed from the sling and hoisting ropes
before the load is lifted.
Center the crane over the load before starting the hoist to avoid swinging the load as
the lift is started. Loads should not be swung by the crane to reach areas not under
the crane.
Crane hoisting ropes should be kept vertical. Cranes shall not be used for side
pulls.
Never lower the block below the point where less than two full wraps of rope remain
on the hoisting drum. Should all the rope be unwound from the drum, be sure it is
rewound in the correct direction and seated properly in the drum grooves or
otherwise the rope will be damaged and the hoist limit switch will not operate to stop
the hoist in the high position.
J4.20
Be sure everyone in the immediate area is clear of the load and aware that a load is
being moved. Sound the warning device (if provided) when raising, lowering or
moving loads wherever people are working to make them aware that a load is being
moved.
Do not make lifts beyond the rated load capacity of the crane, sling chains, rope
slings, etc.
Do not operate the crane if limit switches are out of order, or if ropes show defects or
wear.
Make certain that before moving the load, load slings, load chains, or other lifting
devices are fully seated in the saddle of the hook with hook latch closed (if equipped
with hook latch).
When a duplex hook (double saddle hook) is used, a double sling or choker should
be used to assure that the load is equally divided over both saddles of the hook.
On all capacity or near capacity loads, the hoist brakes should be tested by returning
the master switch or push button to the OFF position after raising the load a few
inches off the floor. Check the load for drift. If no drift, lower the load halfway to the
floor and stop. Again check for drift. If load drift is noticed in either step, lower the
load to the floor and report the situation immediately to the supervisor.
Check to be sure that the load and/or bottom block is lifted high enough to clear all
obstructions when moving bridge or trolley.
At no time should a load be left suspended from the crane unless the operator is at
the master switches or push button with the power on, and under this condition keep
the load as close as possible to the floor to minimize the possibility of an injury if the
load should drop. When the crane is holding a load, the crane operator should
remain at the master switch or push button.
When a hitcher is used, it should be the joint responsibility of the crane operator and
the hitcher to see that hitches are secure and that all loose material has been
removed from the load before starting a lift.
Do not lift loads with any sling hooks hanging loose. (If all sling hooks are not
needed, they should be properly stored, or use a different sling.)
All slings or cables should be removed from the crane hooks when not in use.
(Dangling cables or hooks hung in sling rings can inadvertently snag other objects
when the crane is moving.)
Crane operators should not use limit switches to stop the hoist under normal
operating conditions. (These are emergency devices and shall not be used as
operating controls.)
J4.21
Do not block, adjust or disconnect limit switches in order to go higher or lower than
the switch will allow.
Upper limit switches (and lower limit switches, when provided) should be tested in
stopping the hoist at the beginning of each shift, or as frequently as otherwise
directed.
Operators shall not carry loads and/or empty bottom blocks over personnel.
Particular additional caution should be practiced when using magnet or vacuum
devices. Loads, or parts of loads, held magnetically could drop. Failure of power to
magnets or vacuum devices can result in dropping the load.
If the electric power goes off, place your controllers in the OFF position and keep
them there until power is again available.
Before closing main or emergency switches, be sure that all controllers are in the
OFF position so that the crane cannot start unexpectedly.
If plugging protection is not provided, always stop the controllers momentarily in the
OFF position before reversingexcept to avoid accidents. (The slight pause is
necessary to give the braking mechanism time to operate.)
Whenever the operator leaves the crane this procedure should be followed:
Raise all Hooks to an intermediate position
Spot the crane at an approved designated location
Place all controls in the OFF position
Open the main switch to the OFF position
Make visual check before leaving the crane
Note: On yard cranes (cranes on outside runways), operators should set the brake and
anchor securely so the crane will not be moved by the wind.
When two or more cranes are used in making one lift, it is very important that the
crane operators take signals from only one designated person.
Never attempt to close a switch that has an OUT OF ORDER or DO NOT
OPERATE card on it. Even when a crane operator has placed the card, it is
necessary to make a careful check to determine that no one else is working on the
crane, before removing the card.
In case of emergency or during inspection, repairing, cleaning or lubricating, a
warning sign or signal should be displayed and the main switch should be locked in
the OFF position. This should be done whether the work is being done by the
crane operator or by others. On cab-operated cranes when others are doing the
J4.22
work, the crane operator should remain in the crane cab unless otherwise instructed
by the supervisor.
Never move or bump another crane that has a warning sign or signal displayed.
Contacts with runway stops or other cranes shall be made with extreme caution.
The operator should do so with particular care for the safety of persons on or below
the crane, and only after making certain that any persons on the other cranes are
aware of what is being done.
Do not change fuse sizes. Do not attempt to repair electrical apparatus or to make
other major repairs on the crane unless specific authorization has been received.
Never bypass any electrical limit switches or warning devices.
Load limit or overload devices shall not be used to measure loads being lifted. Since
this is an emergency device, it shall not be used as a production operating control.
Sling Inspection
Wire Rope
Sling inspections are intended to detect serious damage or deterioration to the sling, which
may lower the rated capacity or weaken the sling. The inspection shall be conducted by a
qualified operator or riggers prior to use, and documented on our wire rope sling inspection
form (see Attachment 2 or Hazard Assessment Checklist (Shop)).
Sling shall be immediately removed from service if any of the following conditions are
present:
Broken wires: For a single part sling, 10 randomly distributed broken wires in one
rope lay, or five broken wires in one strand of one rope lay.
Metal loss: Wear or scraping of one-third (1/3) of the original diameter of outside
individual wires.
Distortion: Kinking, crushing, birdcaging or other damage which distorts the rope
structures.
Evidence of heat damage.
End attachments that are cracked, deformed or worn.
Hooks that have been opened more than 15 percent of the normal throat opening
measured at the narrowest opening measured at the narrowest point or twisted more
than 10 degrees from the plane of the unbent hook.
Corrosion of the rope or end attachments.
J4.23
Web Slings
Web slings shall be inspected prior to each use (visually) and documented on the Daily
Cherry Picker Checklist (see Attachment 1 or Hazard Assessment Checklist (Shop)). The
operating area shall maintain a certification of the load test on file for each sling.
Each sling shall be marked or coded to show the rated capacities for each type hitch and
uniform thickness and width.
When synthetic web slings are used the following precaution shall be taken:
Nylon web slings shall not be used where fumes, vapors, sprays, mists or liquids of
acids or phenolics are present.
Polyester and polypropylene web slings shall not be used where fumes, vapor,
sprays, mists or liquids of caustics and present.
Web slings with aluminum fitting shall not be used where fumes, vapor, sprays,
mists or liquids of caustics and present.
Web slings, which are repaired, shall not be used unless repaired by the sling
manufacturer. Repaired slings shall be proof tested by manufacturer to twice the rated
capacity. The manufacturer shall provide, for the employers records, a certificate of the
test.
Synthetic web slings shall be immediately removed from service if any of the following
conditions are present.
Acid or caustic Burns.
Melting or charring of any part of the sling surface.
Snags, punctures, tears or cuts.
Broken or worn stitches or
Distortion of fitting.
Chain Slings
Alloy steel chain slings grade 80 or 100 shall be used for any type of lifting
Transport chain slings grade 70 or 700 shall only be used for binding down loads for
transportation. Under no circumstance shall transport chain slings be used for lifting.
Alloy steel chain slings, Grade 80 or 100, shall have permanently affixed durable
identification stating size, grade, rated capacity and reach. Chain slings attachments shall
have a rated capacity at least equal to that of the alloy chain sling. Make shift links,
fasteners or attachments shall not be used. Individuals shall not use alloy chain slings with
loads, which exceed the rated capacity of the sling.
J4.24
Inspection shall be conducted prior to each use and a documented inspection conducted
weekly (see Attachment 4 or Hazard Assessment Checklist (Shop)). Each chain sling shall
be re-certified on an annual interval.
Rigging Practices
Only employees who have completed Dynamic Industries or a designated Rigger
course may perform rigging operations and perform Pre-use inspections of rigging
and rigging equipment to ensure the rigging is safe to be used.
Sling angles will not be less than 30 degrees from the horizontal (or not more than
60 degrees from the vertical).
(See Attachment 5 for proper sling angle
calculations.) Never use slings for loads that weight more than the rating of the sling.
NO "field fabricated" slings shall be used.
Knots or kinks are not permitted in wire rope or slings for any reason.
Slings and wire rope must not be used and removed from service if they have no
certification tag or matching certification documents, any excessive amount of wear,
damage, flat spots, broken wires, or visual lack of lubrication exist and must be
certified and tagged. If any of the above conditions are present, the equipment will
be replaced or sent in for inspection, testing, and refurbishment by qualified
personnel.
Chains, fiber rope, or "soft line" shall not be used in the place of wire rope slings to
lift loads or personnel. Appropriately rated nylon or synthetic webbed slings are
acceptable for non-personnel lifts.
Wire rope and slings shall not contact any rough cut edges or holes such as pad
eyes and shall be padded or properly protected to prevent damage from contact by
sharp corners. Shackles must be used with all pad eyes.
Hook openings shall be turned outward on hook slings. (see Attachment 5)
Tag lines shall be used on all lifts. They shall be of sufficient length, diameter, and
strength to allow adequate control of the load by the rigger(s).
The free end of tag lines should not contain anything that is likely to become
snagged during lifting operations (e.g., knots or weights).
Tag lines should be connected to the lowest practical point and at right angles on the
load whenever possible. If a tag line cannot be attached directly to the load, it must
be attached to the shackle end of the sling as near the load as possible.
Slings and tag lines must be clear of all obstructions before the signal person and/or
rigger divert their attention from the load.
J4.25
(see
Rigging and rigging equipment shall be stored in designated locations when not in
use.
Shackle Information
There are two types of shackles commonly used in rigging. They are the anchor
(bow type) shackle and chain ("D" type) shackle. The pin styles commonly used
with shackles are screw pins, bolt pins, and loose pins. Shackles, like most other
rigging hardware, are sized by the diameter of the steel in the bow section rather
than the pin size.
Only screw type pins are accepted on Dynamic Industries locations for rigging and
lifting operations.
Only high strength alloy steel shackles are to be used in lifting operations
Attachment 5).
(see
Only properly fitted screw pins shall be used in shackles. Never replace the shackle
pin with a bolt.
Shackles should never be used if the distance between the eyes is greater than
listed in Appendix C.
All screw pins must be straight and completely seated in the shackle.
Shackles worn in the crown or the pin by more than 10% of the original diameter
shall be discarded.
Shackles should never be attached where the load could possibly roll or unscrew the
pin during the lifting process.
Shackle specifications: (see Attachment 5)
Suspended Personnel Man Baskets/Platforms
General
Personnel are allowed to work from approved suspended personnel baskets only.
Hoisting of personnel should be performed in a slow, controlled, and cautious
manner.
J4.26
The number of personnel occupying the personnel platform shall not exceed the
number of employees required to do the job.
Personnel platforms shall be used only for employees, their tools, and the materials
necessary to do their work.
Materials and tools shall be evenly distributed and secured to prevent displacement.
Rigging
Crane hooks used to lift suspended work baskets will have a positive locking device
(not a spring loaded flap or clip)
Rigging for a suspended personnel basket will be installed to minimize tipping over
regardless of location of personnel in the basket.
All slings, shackles, and wire rope must be inspected and rated for 5 times the
baskets maximum rated load capacity. If rotational resistant rope is used, it must
support at least 10 times the maximum load.
All eyes of wire rope slings shall be fabricated with thimbles.
All rigging for personnel platforms must be used only for the personnel platform.
All shackles incorporated in a Personnel Basket lifting configuration will be tight and
wire locked.
Before personnel are lifted in platform, the rope hoist shall be free of kinks, multiple
part lines must not be twisted, primary attachment must be centered over the
platform, and the hoist system should be inspected for any slack in the line.
A complete inspection of the crane, rigging, and personnel platform must be
completed after the trial test. If any deficiencies or modifications to the crane,
rigging, or personnel platform are found, another trial test must be performed.
Work practices
Before employees enter or exit the personnel platform that is not landed, the basket
must be secured to the structure unless this creates an unsafe situation.
All personnel working in suspended personnel baskets over water must wear an
approved life preserver that is properly donned.
Workbaskets will be equipped with tag lines free of knots unless they create an
unsafe condition.
The operator must remain at the controls at all times the personnel platform is
occupied.
Hoisting of personnel should be promptly stopped upon indication of dangerous
weather.
Personnel being hois-pted shall remain in continuous sight of and in direct
communication with the operator or signal person. If this is not possible, radio
communication alone can be used.
All employees are required to wear fall protection at all times while being lifted on
personnel platforms.
No lifts shall be made on any of the cranes other hoists while the personnel platform
is attached to the crane.
All personnel lifting operations shall be shut down when wind speeds are equal to or
greater than 25 mph.
Traveling
Hoisting employees while the crane is traveling is prohibited.
J4.29
Attachment 1
J4.30
J4.30.a.1
Attachment 2
J4.31
CHERRY PICKER #
VISUAL CHECKS:
OK
NO
LOGBOOK
REMOVE
FROM
SERVICE
OK
REMOVE
FROM
SERVICE
OK
REMOVE
FROM
SERVICE
OK
REMOVE
FROM
SERVICE
HOIST MOUNTING
FIRE EXTINGUISHER
OK
OK
PEDESTAL MOUNTING
AFTER STARTING ENGINE
NO
STEERING
BRAKES
OK
REMOVE
FROM
SERVICE
OUTRIGGERS
LOAD BRAKE
Stretched)
BOOM
OK
REMOVE
FROM
SERVICE
*NOTE:
1. Repair deficiency(ies) if authorized to perform maintenance.
2. Explain deficiency(ies) in REMARKS.
3. Remove cherry picker from service
4. Place a completed white DO NOT USE tag on the steering wheel.
5. Submit checklist to supervisor for handling.
REMARKS:
J4.31.a.1
CRAWLER CRANE#
VISUAL CHECKS
NO
OK
REMOVE
FROM
SERVICE
OK
YES
NO
PREVENTIVE MAINTENANCE
RADIATOR COOLANT
ENGINE OIL
AIR COMPRESSOR
NO
OK
NO
Has the hook been opened more than 15% of normal throat opening measured at the narrowest
point?
Is the hook twisted more than 10 degrees from the plane of the unbent hook?
REMARKS:
J4.31.a.2
Size:
Job#:
Location:
CHECK
OUT
YES NO
Is the identification tag attached to sling?
Has the hook been opened more than 15% of normal throat
opening measured at the narrowest point?
Is the hook twisted more than 10 degrees from the plane of the
unbent hook?
CHECK IN
YES
NO
Inspector
Inspector Signature
Date:
J4.31.a.3
Attachment 3
J4.32
Weight of Load:
_________________________________
Weight of Lifting Tackle: _________________________________
Boom Angle:
_________________________________
TOTAL LIFT IS _____% OF THE CRANES RATED CAPACITY
Sea state & wave conditions:
Environmental Conditions:
This lift plan shall be utilized for lifts grater than 50% of the cranes rated capacity, if two or more cranes
are used or if other conditions warrant a critical lift.
Verified by:
Operator Name:
A. WEIGHT
1.
2.
3.
4.
5.
D. RIGGING (Continued)
_________lbs.
_________lbs.
_________lbs.
_________lbs.
_________lbs.
_________lbs.
____________________________________
2.
3.
4.
5.
B. CRANE PLACEMENT
1.
2.
E. CRANE
1.
2.
3.
Shackle Selection
a. Type of Shackle: __________________
b. Capacity (tons): ___________________
c. Shackle Attached to the Load By:
________________________________
d. Number of Shackles: _______________
Rigged for center of load? Yes ____ No ___
All Rigging Inspected? Yes ____ No ____
Sling Angles within Capacity Limits?
Yes ____ No ____
4.
5.
6.
D. RIGGING
1.
Sling Selection
a. Type of Arrangement _______________
b. Number of Slings in Hook-up ________
c. Sling Size ________________________
d. Sling Length ______________________
e. Rated Capacity of Sling _____________
Yes No
[ ] [ ]
Swing Room
[ ] [ ]
Head Room Checked
[ ] [ ]
Load Secured & Stable
Tag Line Used
[ ] [ ]
Exp./Designated signal man
[ ] [ ]
[ ] [ ]
Experienced Rigger
[ ] [ ]
Area Barricaded
Load Chart in crane
[ ] [ ]
All personnel in area notified
Wind Conditions _____________________
Helicopter Concerns: __________________
* When lifting from a vessel, the dynamic load chart should always be used!
J4.32.a.1
MINIMU
WIRE
M
ROPE
SHACKL
SIZE
E SIZE
(in.)
(in.)
TWO LEG OR
60 DEGREE
45 DEGREE
30 DEGREE
BASKET HITCH
SLING ANGLE
SLING ANGLE
SLING ANGLE
1120
820
2200
1940
1500
1100
5/16
3/8
1740
1280
3400
3000
2400
1700
7/16
2400
1840
4800
4200
3400
2400
1/2
3400
2400
6800
5800
4800
3400
5/8
4400
3200
8800
7600
6200
4400
5/8
5600
4000
11200
9600
7900
5600
3/4
6800
5000
13600
11800
9600
6800
7/8
9800
7200
19600
16900
13800
9800
1
13200
9600
26400
22800
18600
13200
1-1/8
17000
12600
34000
30000
24000
17000
1-1/4
20000
15800
40000
34600
28300
20000
1-3/8
26000
19400
52000
45000
36700
26000
1-1/2
30000
24000
60000
52000
42400
30000
1-1/2
34000
26000
70000
60000
50000
34000
1-3/4
48000
36000
94000
82000
66000
48000
2
60000
46000
122000
106000
86000
60000
NOTE: HORIZONTAL SLING ANGLES OF LESS THAN 45 DEGREES ARE NOT RECOMMENDED
VERTICAL
1/4
7/16
3/8
7/16
1/2
9/16
5/8
3/4
7/8
1
1-1/8
1-1/4
1-3/8
1-1/2
1-3/4
2
CHOKER
Work
Pin
(A)
Load
Limit
tons
1/5
1
1.1/2
2
3.1/4
4.3/4
6.1/2
8.1/2
9.1/2
12
13.1/2
17
25
35
45
55
85
Diam.
(B)
Appro
x.
Weight
Each
3/16
.05 lbs.
5/16
0.13
5/16
3/8
0.21
3/8
7/16
0.33
7/16
0.47
5/8
0.76
5/8
1.44
7/8
2.3
7/8
1
3.5
1
1.1/8
5
1.1/8
1.1/4
7
1.1/4
1.3/8
9.5
1.3/8
1.1/2
13
1.1/2
1.5/8
16.5
1.3/4
2
29
2
2.1/4
43
2.1/4
2.1/2
59.4
2.1/2
2.3/4
86
3
3.1/4
119.5
Design Factor 6:1
Do not use screw pin shackles if the pin can roll and unscrew under load.
CAUTION: NEVER EXCEED SAFE WORKING LOAD LIMIT
Dimensions in Inches
7/8
1.1/16
1.1/4
1.7/16
1.11/16
1.7/8
2.5/16
2.7/8
3.7/16
3.7/8
4.3/16
4.11/16
5.1/4
5.5/8
7.1/8
8
8.3/4
10.1/4
13
3/8
15/32
17/32
5/8
13/16
13/16
1.1/16
1.3/16
1.1/2
1.5/8
1.13/16
2
2.3/16
2.5/16
3
3.1/8
3.3/4
4.1/4
4.7/8
15/32
21/32
13/16
15/16
1.1/8
1.1/4
1.9/16
1.7/8
2.1/8
2.3/8
2.9/16
2.7/8
3.1/4
3.1/2
4.5/16
5
5.1/4
5.7/8
7.1/4
5/8
27.32
1
1.1/8
1.1/4
1.5/8
1.15/16
2.1/4
2.5/8
2.15/16
3.1/8
3.3/8
3.3/4
5
5.5/8
5.1/2
7.1/8
7.7/8
Add/Rev 6/00
J4.32.a.2
Attachment 4
J4.33
Size:
Type:
Job#:
Location:
Dept:
3/8
5/8
7/8
1
1 1/8
1
1 3/8
1
1 3/4
YES
64
19
64
25
64
31
64
19
32
REMOVE FROM
SERVICE
OK
4 5 64
13
16
29
32
1
13
32
13
16
13
1 32
NO
Inspector:
Inspector Signature:
Date:
J4.33.a.1
Attachment 5
J4.34
J4.34.a.1
Attachment 5 - Continued
J4.34.a.2
Attachment 5 - Continued
J4.34.a.3
Attachment 5 - Continued
J4.34.a.4
Attachment 5 - Continued
J4.34.a.5
Attachment 5 Continued
J4.34.a.6
Attachment 5 - Continued
J4.34.a.7
Attachment 6
J4.35
PERSONNEL PLATFORM #:
TIME:
CRANE:
LOCATION:
CRANE OPERATOR:
BASKET INSPECTION
PASS
FAIL
SLING INSPECTION
PASS
FAIL
*NOTE: TEST LIFT MUST BE DONE IN ALL LOCATIONS THAT ARE TO BE REACHED FROM THE PLATFORM
J4.35.a.1
Attachment 7
J4.36
J4.36.a.1
J4.36.a.2
Page: 1 of 18
Original: 01/01/2002
Revised: 02/15/2007
J5.1
Periodic auditing, with the assistance of the Safety, Health and Environmental
Department, of work sites and activities where this program will be
implemented.
Ensure that all electrical cords and welding leads are kept up to date with
Monthly Color Coding as identified in Attachment 2 of this procedure.
The Safety, Health and Environmental Department is responsible for:
Assist management in implementation of the Electrical Safety Program.
Assist management in the monitoring and auditing of employees in the
adjustment, repair or replacement of electrical components.
Audit the Electrical Safety Program, with the assistance of management,
periodically, or whenever changes are made, to the program or processes
that they pertain to change.
Assist management in any changes that are necessary to the Electrical
Safety Program.
The Employee is responsible for:
Following all appropriate rules pertaining to the Electrical Safety Program.
Reporting any injury, incident or near miss to the Supervisor or Safety, Health
and Environmental Department.
Definitions
Qualified Worker: An employee trained and authorized to conduct electrical work.
Unqualified: Employees who have not been trained or authorized by management
to conduct electrical work.
Static Electricity: Electrification of materials through physical contact and
separation and the various effects resulting from the positive and negative charges
so formed. Static is generated when liquids move in contact with other materials,
such as in pouring, mixing, pumping, filtering, or agitating.
Static Spark: An impulsive discharge of electricity across a gap between two points
not in contact.
Bonding: The process of connecting two or more conductive objects together by
means of a conductor to minimize potential differences between conductive objects.
Bonding equalizes the potential between objects.
J5.2
Non-electrical
(Lockout/Tagout).
All qualified employees will follow established electrical safety procedures and
precautions.
Protective Equipment
Qualified employees will wear electrically rated safety shoes/boots and head
protection.
All tools used for electrical work shall be properly insulated.
Electrical rated gloves shall be available for work on electrical equipment.
Flash protection shall be available for all work in which it is required.
Electrically rated matting will be installed in front of all distribution panels in
electric utility rooms.
J5.4
J5.5
When to test
Upon indication that insulating value is
suspect.
Upon indication that insulating value is
suspect.
Before first issue and every 12 months
Before first issue and every 6 months
Before first issue and every 12 months
harnesses with 100% tie off with the use of double lanyards. Proper anchor points
shall be used when fall protection with the use of safety harnesses is utilized.
Portable ladders shall have non-conductive siderails if they are used where the
employee or the ladder could contact exposed energized parts.
General Protective Equipment and Tools
General protective equipment and tools shall be used when in the proximity of, or
working on, exposed energized parts. The following rules apply:
1. When working on or near exposed energized parts, Qualified Employees
shall use insulated tools or handling equipment suitable for the voltage
present and working equipment. In cases where the insulation may be
damaged, a protective outer layer should be employed.
2. Conductive jewelry and clothing may not be worn if they might contact any
exposed energized parts.
3. Fuse handling equipment, insulated for the circuit voltage, shall be used to
remove or install fuses when the terminal is energized.
4. Ropes and other handlines used near exposed energized equipment shall
be non-conductive.
Warnings and Barricades
Warnings and barricades shall be employed to alert unqualified Employees of the
present danger related to exposed energized parts. The following rules apply:
1. Safety signs, warning tags, etc., must be used to warn Unqualified
Employees of the electrical hazards present, even temporarily, that may
endanger them.
2. Non-conductive barricades shall be used with safety signs to prevent
Unqualified Employees access to exposed energized parts or areas.
3. Where barricades and warning signs do not provide adequate protection
from electrical hazards, an Attendant shall be stationed to warn and
protect Employees.
Powered Equipment Safety Rules
Electrical equipment is defined as cord or plug-type electrical devices, which
includes the use of flexible or extension cords. Examples of portable electrical
equipment included powered hand tools, powered bench tools, fans, radios, etc. The
following safety rules apply to portable electrical equipment (PEE):
1. PEE shall be handled in such a manner as to not cause damage. Power
cords may not be stapled or otherwise hung in a way that may cause
damage to the outer jacket or insulation.
J5.7
2. PEE shall be visually inspected for damage, wear, cracked or spilt outer
jackets or insulation, missing or damaged plugs, etc., before use or before
each shift. PEE that remains connected once put in place need not be
inspected until relocated. Any defects; such as cracked or split outer
jackets, deformed or missing plug or insulation must be repaired, replaced
or placed out of service until repairs can be made. When taken out of
service, ensure tag is placed on equipment identifying the damage. Only
PEE that are color coded with the correct month color should be used. If
equipment does not have the appropriate color code, it needs to be
brought to supervisor for appropriate inspection.
3. In the event a GFCI cannot be used as outlined in #8 below, all equipment
grounding conductors used in that circuit shall be tested for continuity and
shall be electrically continuous. These tests shall be done monthly, after
repairs are made, or after cords in that circuit may be suspected of
damage such as when it has been run over. PEE that does not meet the
requirements of this section must be removed from service and not be
made available for use by employees.
4. If testing is required due to not using a GFCI, such tests shall be recorded
as to the identity of the cords and/or receptacles that passed the test and
shall include the date tested, the qualified person that performed the
test/inspection, and colored tape will be affixed to the cord indicating the
month of the inspection.
5. Always check the compatibility of cord sets and receptacles for proper
use.
6. Ground type cord sets may only be used with ground type receptacles
when used with equipment requiring a ground type conductor.
7. Attachment plugs and receptacle may not be altered or connected in a
way that would prevent the proper continuity of the equipment grounding
conductor. Adapters may not be used if they interrupt the continuity of the
grounding conductor.
8. Use of Ground Fault Circuit Interrupters (GFCI) shall be utilized on all 120
Volt, single phase, 15 and 20 ampere receptacle outlets on construction
sites, which are not part of the permanent wiring of the building or
structure and which are in use by employees. Receptacles on a two-wire
single phase portable or vehicle mounted generator rated not more than
5kW, where the circuit conductors of the generator are insulated from the
generator frame and all other grounded surfaces, need not be protected
with ground-fault circuit interrupters.
9. Only portable electrical equipment that is double insulated or designed for
use in areas that are wet or likely to contact conductive liquids may be
used.
J5.8
10. Employees that are wet or have wet hands may not handle PEEs (plug-in,
un-plug, etc.). Personal protective equipment must be used when handling
PEEs that are wet or covered with a conductive liquid.
11. Locking-type connectors shall be properly secured after connection to a
power source.
12. Routing of lines shall be made in such a way where cords do not come in
contact with water sources and do not obstruct walkways.
Electrical Circuit Safety Procedures
Electrical power and lighting circuits are defined as devices specifically designed to
connect, disconnect or reverse circuits under a power load condition. When these
circuits are employed, the following rules apply:
1. Cable connectors (not of load-break type) fuses, terminal plugs or cable
splice connectors may not be used, unless an emergency, to connect,
disconnect or reverse in place of proper electrical circuits.
2. After a protective circuit is disconnected or opened, it may not be
connected or closed until it has been determined that the equipment and
circuit can be safely energized.
3. Overcurrent protectors of circuits or connected circuits may not be
modified, even on a temporary basis, beyond the installation safety
requirements.
4. Only Qualified Employees may perform test on electrical circuits or
equipment.
5. Test equipment and all associated test leads, cables, power cords, probes
and connectors shall be visually inspected for external damage before
use. Any damage or defects shall be repaired before use or placed out of
service.
6. Test equipment shall be rated to meet or exceed the voltage being tested
and fit for the environment in which it is being used.
7. Where flammable or ignitable materials are stored, even occasionally,
electrical equipment capable of igniting them may not be used unless
measures are taken to prevent hazardous conditions from developing.
Standard Operating Procedure
Electrical Pre-Work Procedure
Except in extreme cases, work on electrical equipment will be done with all electrical
circuits in the work area de-energized by following the Energy Isolation procedure.
When working on or near energized electrical circuits with less than 30 volts to
J5.9
2. Warn employees exposed to the hazards associated with reenergizing the circuit or equipment to stay clear of circuits and
equipment.
3. Remove each lock and tag. They shall be removed by the
employee who applied it or under his or her direct supervision.
However, if this employee is absent from the workplace, then the
lock or tag may be removed by a qualified supervisor designated to
perform this task provided that:
A. The supervisor ensures that the employee who applied the lock
or tag is not available at the workplace, and
B. The supervisor ensures that the employee is aware that the lock
or tag has been removed before he or she resumes work at that
workplace.
4. Conduct a visual determination that all employees are clear of the
circuits and equipment.
Working Near Overhead Lines
If work is to be performed near overhead lines, the lines shall be deenergized and
grounded, or other protective measures shall be provided before work is started. If
the lines are to be deenergized, arrangements shall be made with the organization
that operates or controls the electric circuits involved to deenergize and ground
them. If protective measures, such as guarding, isolating, or insulating or provided,
these precautions shall prevent employees from contacting such lines directly with
any part of their body or indirectly through conductive materials, tools, or equipment.
When an unqualified person is working near overhead lines, in an elevated position,
such as from an aerial platform, the person and the longest conductive object that
they may be able to contact the line with must not be able to come within ten (10)
feet of overhead line of voltages up to 50,000 volts. For voltages over 50,000 volts,
an addition four (4) inches must be added to the ten (10) feet distance for every
additional 10,000 volts. When unqualified persons are working on the ground in the
vicinity of overhead lines, the above distances still apply. All Moreno Group LLC and
Subsidiaries will be considered Unqualified for work around overhead lines.
Vehicular and Mechanical Equipment
Any vehicle or mechanical equipment, such as cranes and cherry pickers, capable of
having parts of its structure elevated near energized overhead lines shall be
operated so that a clearance of ten (10) feet is maintained. If the voltage is higher
than 50,000 volts, the clearance shall be increased 4 inches for every additional
10,000 volts.
J5.12
J5.13
B.
2. Storage Tanks
A. Avoid overshot splash filling. The outlet of the fill pipe should
discharge near the bottom of the tank with minimum agitation of the
water and sediment on the tank bottom.
B. Where the outlet of the fill line is attached to a downcomer, siphon
breakers that permit air or vapor to enter the downcomer should not be
used. Avoid discharging product from a swing line elevated above the
liquid level. Limit the velocity of the incoming liquid stream to three (3)
feet per second until the fill outlet is well submerged.
C. Ungrounded objects, such as loose gauge floats, should be eliminated.
D. Avoid pumping substantial amounts of air or other entrained gas into
the tank through the liquid.
E. Metallic or conductive hand gauging tapes and sample cans or bottles
on chains may act as spark promoters and shall not be lowered into
tanks that may contain flammable atmospheres during tank loading.
F. Personnel must wait at least five (5) minutes after loading is completed
before conductive gauging or sampling materials are used in the tank.
While gauging or sampling is being performed, the gauge line or
sampling device must remain continuously in contact with the edge of
the thief hatch to form a bond.
G. Bonding straps on gauging tapes shall not be removed and shall be
securely clamped to the thief hatch while gauging is being
accomplished.
H. Metallic tanks that are in contact with the ground are sufficiently
grounded as long as one of the following conditions are met:
1. A tank is connected without insulated joints to a grounded metallic piping
system;
2. A vertical cylindrical tank rests on earth or concrete and is at least 20 feet
(6 meters) in diameter, or rests on bituminous pavement and is at least 50
feet (15 meters) in diameter.
Grounding
1.
Equipment Grounding:
A. The grounding of equipment is primarily for personnel protection and is
required for all metallic housings, enclosures, and structures which
contain electric conductors. Grounding should be interconnected to
the extent that a low potential difference is maintained between nearby
metallic objects.
J5.15
Ground Rods:
A. Information on location and applications requiring ground rods may be
found in NFPA 70, National Electrical Code, and National Electrical
Safety Code.
B. Multiple rods provide a reduction in resistance but may not provide
adequate performance.
J5.16
Attachment 1
J5.17
Hazard
Risk
Category
V-Rated
Gloves
V-Rated
Tools
0
1
N
N
N
N
2*
2*
2*
2*
2*
J5.17.a.1
J5.17.a.2
Hazard Risk
Category
V-Rated
Gloves
V-Rated
Tools
2*
2*
2*
2*
2*
2*
2*
Hazard Risk
Category
V-Rated
Gloves
V-Rated
Tools
J5.17.a.3
Hazard
Risk
Category
V-Rated
Gloves
V-Rated
Tools
Legend:
V-rated gloves are gloves rated and tested for the maximum line-to-line voltage
upon which work will be done.
V-rated tools are tools rated and tested for the maximum line-to line voltage upon
which work will be done.
2* means that a double-layer switching hood and hearing protection are required for
this task in addition to the other Hazard Risk Category 2 requirements of Table 3.
Y = yes (required)
N = no (not required)
Notes:
1. 25-kA short-circuit current available, 0.03-second (2 cycle) fault clearing time.
2. 65-kA short-circuit current available, 0.03-second (2 cycle) fault clearing time.
3. For > 10 kA short-circuit current available, the hazard risk category required
may be reduced by one number.
4. 65-kA short-circuit current available, 0.03-second (2 cycle) fault clearing time.
5. 65-kA short-circuit current available, up to 1.0-second (60 cycle) fault clearing
time.
6. For > 25 KA short-circuit current available, the hazard risk category required
may be reduced by one number.
J5.17.a.4
Attachment 2
J5.18
January
February
March
April
May
June
July
August
September
October
November
December
Red
White
Green
Red
White
Green
Red
White
Green
Red
White
Green
J5.18.a.1
Page: 1 of 11
Original: 01/01/2001
Revised: 01/01/2004
J6.1
Responsibilities
The Facility / Site Manager is responsible for ensuring that the requirements of this
procedure are met.
The Maintenance Department Supervisor is responsible for ensuring that:
Lockable isolating devices or equivalent means are installed on existing
equipment where none are provided, as a minimum, when the equipment is
overhauled.
Maintenance employees affected by this procedure are trained prior to being
involved in any Lock, Tag and Try applications.
Personal locks and tags are obtained and issued for jobs involving Lock, Tag
and Try applications.
The First Line Supervisor / Offshore Superintendent is responsible for ensuring:
Visiting with Client Representatives to establish, which Lockout / Tagout
Procedure will be used. Moreno Group LLC and Subsidiaries will follow their
clients procedure while on their clients location only if their procedure meets
or exceeds Moreno Group LLC and Subsidiaries expectations.
Performing a Lockout / Tagout equipment assessment to ensure all energy
sources are properly lock and tagout. If Moreno Group LLC and Subsidiaries
are following their clients procedure, this assessment shall be conducted with
our clients operations personnel.
Employees who are affected by this procedure are trained prior to being
involved in any Lockout / Tagout applications.
Standardized locks and personal tags are obtained and issued for jobs
involving Lockout / Tagout applications.
All affected personnel are notified of the Lock, Tag and Try application to take
place.
The requirements of this procedure are complied with prior to performing work
on equipment.
The Contractor Representative is responsible for ensuring:
Contractor employees affected by this procedure are properly trained prior to
being involved in any Lock, Tag and Try applications; contractors provide
their own locks and tags
All affected contract personnel including sub-contractors, are notified of the
Lock, Tag and Try applications to take place.
J6.2
The requirements of this procedure are complied with prior to performing work
on equipment.
Contractors are informed of the type of locks and tags specified for use
in the Moreno Group LLC and Subsidiaries facilities / sites.
The Engineering Department is responsible for ensuring that all new machinery or
equipment installed or existing equipment that has been overhauled has identified,
lockable, isolating devices for each energy source involved.
The Safety, Health and Environmental Department is responsible for ensuring
that:
Training programs are made available to the Area / Department Managers for
the training of all facility / site personnel.
Periodic audits are performed to ensure procedure compliance.
The Employee is responsible for ensuring:
The requirements of this procedure are followed for work involved in, on or
around machines or equipment during repair, maintenance, operation or other
related activities.
Individual locks and tags are applied and removed ONLY by the employee to
whom they are assigned.
Before starting work each authorized (exposed) employee shall verify (try)
that the equipment will not start by activating (or witnessing the activation) all
of the start / stop switches.
Definitions
Affected Employee An employee whose job requires the operation or use of a
machine or equipment on which servicing or maintenance is being performed under
lockout or tagout, or whose job requires him/her to work in an area in which such
servicing or maintenance is being performed.
Authorized Employee A person who locks or implements a tagout system to
perform the servicing or maintenance on that machine or equipment. An authorized
employee may be the same person when the affected employees duties also
include performing machine maintenance or service on a machine or equipment,
which must be locked, or a tagout system implemented.
Capable of being locked out An energy isolating device will be considered to be
capable of being locked out either if it is designed with a hasp or other attachment or
integral part to which, or through which, a lock can be affixed, or if it has a locking
mechanism built into it. Other energy isolation devices will also be considered to be
J6.3
capable of being locked out, if lockout can be achieved without the need to
dismantle, rebuild or replace the energy-isolating device or permanently alter its
energy control capability.
Energized Connected to an energy source or containing residual or stored energy.
Energy isolating device A mechanical device that physically prevents the
transmission or release of energy, including but not limited to the following: A
manually operated electrical circuit breaker; a disconnect switch; a manually
operated switch by which conductors and, in an addition, no pole can be operated
independently; a slide gate; a slip blind; a line valve; a block; and any similar device
used to block or isolate energy. The term does not include a push button, selector
switch, and other control circuit type devices.
Energy source Any source of electrical, mechanical, hydraulic, pneumatic,
chemical, thermal, or other energy.
Lockout The placement of a lockout device on an energy isolating device, in
accordance with an established procedure, ensuring that the energy isolating device
and the equipment being controlled cannot be operated until the lockout device is
removed.
Lockout device A device that utilizes a positive means such as a lock, key type, to
hold an energy isolating device in the safe position and prevent energizing of a
machine or equipment.
Normal production equipment The utilization of a machine or equipment to perform
its intended production function.
Servicing and/or maintenance Workplace activities such as constructing, installing,
setting up, adjusting, inspecting, modifying, and maintaining and/or servicing
machines or equipment. These activities include lubrication, cleaning, unjamming
machine, equipment and making adjustments or tool changes, where the employee
may be exposed to the unexpected energization or startup of the equipment or
release of hazardous energy.
Setting up Any work performed to prepare a machine or equipment to perform its
normal production operation.
Tagout The placement of a tagout device on an energy isolating device, in
accordance with an established procedure, to indicate that the energy isolating
device and the equipment being controlled may not be operated until the tagout
device is removed.
Tagout device A prominent warning device, such as a tag and a means of
attachment, which can be securely fastened to an energy isolating device in
accordance with an established procedure, to indicate that the energy isolating
device and the equipment being controlled may not be operated until the tagout
device is removed.
J6.4
name and date of placement. On those jobs where an energy isolation device
cannot be locked out, a tagging system shall be implemented.
Group Lockbox A lockbox shall be a durable box fitted with a closure capable of
accepting a scissors device. A lockbox will be used when implementing a Group
Lockout Procedure.
Requirements
Each authorized employee shall survey the equipment to locate and identify all
isolating devices to be certain which energy isolating device(s) needs a lockout
device. The following are some examples of energy isolation devices:
Block Valves (ball and gate valves)
Circuit Breakers
Plugs
More than one of the above energy isolating devices may be combined to isolate the
machine or equipment, i.e. block valves and circuit breaker.
Prior to isolating the equipment each authorized employee shall understand the
effects of isolating the equipment, i.e. alarms, hazards of the energy being
controlled, and means of controlling the equipment.
The authorized employee shall notify the affected employee(s) of the intent to
shutdown the equipment and the energy isolation procedure being used to isolate
the equipment. At this time the equipment may be shutdown by the normal
shutdown procedures.
Each authorized employee shall ensure the equipment is being isolated from its
energy source. The following are some examples but are not limited to:
Turning an equipments circuit breaker to its off position.
Removing the equipments fuses.
Disconnecting lines.
Blocking the pneumatic pressure containing lines and gravity feed lines.
(Remember to bleed off residual pressure.)
Each authorized employee shall verify each energy-isolating device is in a safe or off
position prior to affixing his or her personal lock(s) and yellow tag(s) on each energyisolating device. The lockout device shall be placed on the energy isolating
device(s) to ensure it is held in a safe or off position. If the energy isolating device(s)
are incapable of being locked, a yellow tag shall be positioned by each authorized
employee on the energy isolating device(s) or located as close to the device(s).
J6.6
Each authorized employee shall maintain possession of their key at all times and for
a tagout situation the yellow tag.
After isolating the machine or equipment, all potential hazardous stored or residual
energy shall be relieved, disconnected, restrained, and otherwise rendered safe. If
there is a possibility of re-accumulation of stored energy to a hazardous level,
verification of isolation shall be continued until the servicing or maintenance is
completed or until the possibility of such accumulation no longer exists.
Lockout or Tagout Removal Procedure
Before lockout or tagout devices are removed and energy is restored to the machine
or equipment, the authorized employee(s) shall ensure the following:
Inspect the work area to ensure that nonessential items (i.e. tools, parts, etc.)
have been removed and to ensure that machine or equipment components
are operationally intact.
The work area shall be checked to ensure that all employees have been
safely positioned or removed.
Before lockout or tagout devices are removed and before machines or
equipment are energized, affected employees shall be notified that the
lockout or tagout device(s) have been removed. Only the authorized
employee who applied the lockout or tagout device(s) shall remove them.
If the authorized employee is not available to remove the lockout or tagout device(s),
the device(s) may be removed by the supervisor of the employee or the supervisor
of the facility providing the following procedures are followed and documented:
Verification by the supervisor that the authorized employee(s) who applied the
device are not at the facility.
Make a reasonable effort to contact the authorized employee to inform
him/her that their lockout or tagout device(s) have been removed.
Ensure authorized employee(s) have the knowledge that their lockout or
tagout devices(s) have been removed before they resume work at that facility.
If the situation the lockout or tagout device(s) need to be temporarily removed to test
or reposition the machine or equipment, the following procedures shall be followed:
Clear the machine or equipment of tools or materials.
Remove employees
Remove the lockout or tagout device(s) per our Energy Isolation Procedure.
J6.7
Each employee working on the machine or equipment has reviewed and agrees with
the system, they shall place their personal lock and yellow tag on the lockbox.
These employees shall maintain possession of the key at all times.
Prior to starting work on machines or equipment that have been locked out or tagged
out, the authorized employee(s) shall verify that isolation and de-energization of the
machine or equipment have been accomplished. Then the employee(s) may place
their lock and tag in the lockout box.
Before lockout or tagout device(s) are removed and energy is restored to the
machine or equipment, the employees shall ensure the following:
Inspect the work area to ensure that nonessential items (i.e. tools, parts, etc)
have been removed and to ensure that the machine or equipment
components are operationally intact.
The work area shall be checked to ensure that all employees have been
safely positioned or removed.
Before lockout or tagout device(s) are removed and before machines or
equipment are energized, affected employees shall be notified that the
lockout or tagout device(s) have been removed. Only the employee who
applied the lockout or tagout device(s) shall remove the device(s).
If an employee is not available to remove the lockout or tagout device(s), the
device(s) shall be removed following the above-mentioned Lockout or Tagout
Removal Procedure.
Shift Change
The authorized employee(s) shall remove their lockout or tagout device(s) prior to
leaving the location. The oncoming authorized employee(s) shall review the
machine or equipment per the Energy Control Procedure and attach their personal
lockout or tagout device(s) on the machine or equipment or in the group lockout box.
Cord and Plug Procedure
When work is being performed on cord and plug connected electrical equipment for
which an exposure to the unexpected energization or start-up of the equipment is
controlled by unplugging of the equipment from the source, the plug must remain in
exclusive control (in the employees line of sight) of the employee performing the
servicing or maintenance. If the employee is unable to maintain exclusive control of
the cord or plug, the employee shall follow this procedure to control the energy.
J6.9
Periodic
Annually an inspection shall be conducted to ensure this energy control procedure is
being followed properly. This inspection should include the following elements:
Date
Equipment being isolated
Employees and Inspectors Names
Major Replacement, Repair, Renovation or Modification of Equipment
Whenever major replacement, repair, renovation or modification of machines or
equipment is performed and whenever new machines or equipment are installed,
energy isolating devices for such machines or equipment shall be designed to
accept a lockout device.
Training
Upon hire New Employees will receive Lockout / Tagout training during the New
Employee Orientation / SH&E Training. Refresher training shall be conducted
annually by the First Line Supervisor. Upon a reassignment or a program
deficiencies retraining will be conducted.
Simple Procedure
Moreno Group LLC and Subsidiaries Energy Isolation Procedure
1.
Each authorized employee(s) shall inform operations for the reason of the
energy isolation and review the work area.
2.
Each authorized employee will affix their personal lockout or tagout devices) to
each energy isolating device so that it will secure the energy isolating device(s)
in a Safe or Off position.
3.
4.
Each authorized employee shall remove their personal energy isolating lockout
device(s) and shall attach to each energy isolation device a completed white
Do Not Operate tag, meaning the equipment is secured for operation
purposes only.
5.
J6.10
Upon arrival to job location and prior to resuming incomplete task or relieving
previous shift
6.
Each authorized employee shall inform operations of the reason for the energyisolating task and review the work area.
7.
Operator shall remove all operation lock(s) and associated, white Do Not
Operate tags.
8.
J6.11
Excavation and
Trenching Procedure
Page: 1 of 15
Original: 01/01/2002
Revised:
J7.1
The First Line Supervisor i.e. (Designated Competent Person) or designee for
excavation activities is responsible for:
Making daily inspections of excavations, adjacent areas, and protective
systems for evidence of a situation that could result in possible cave-ins,
indications of failure of protective systems, hazardous atmospheres or other
hazardous conditions.
Making follow-up inspections as needed throughout the shift and after every
rainstorm or other hazard increasing occurrence.
Ensuring appropriate permits have been obtained prior to beginning work.
Initiating the use of additional safeguards as specified in permits or Safe
Operating Procedures (SOPs).
Removing personnel from the trench or excavation if there is evidence of a
situation that could result in a possible cave-in, failure of protective systems,
hazardous atmospheres, or other hazardous condition.
Designate an employee(s) as flag person to direct vehicular or equipment
traffic.
The Safety, Health and Environmental Department is responsible for:
J7.2
Definitions
Benching - a method of protecting employees from cave-ins by excavating the sides
of an excavation to form one or a series of horizontal levels or steps, usually with
vertical or near vertical surfaces between levels.
Cave-in - the separation of a mass of soil or rock material from the side of an
excavation, or the loss of soil from under a trench shield or support system, and its
sudden movement into the excavation, either by failing or sliding, in sufficient
quantity so that it could entrap, bury, or otherwise injure and immobilize a person.
Cemented Soil means a soil in which the particles are held together by a chemical
agent, such as calcium carbonate, such that a hand-size sample cannot be crushed
into powder or individual soil particles by finger pressure.
Cohesive Soil means a soil (fine grained soil), or soil with a high clay content,
which has cohesive strength. Cohesive soil does not crumble, can be excavated with
vertical sideslopes, and is plastic when moist. Cohesive soil is hard to break up
when dry, and exhibits significant cohesion when submerged. Cohesive soils include
clayey slits, sand clay, silty clay, clay and organic clay.
Competent Person - one who is capable of identifying existing and predictable
hazards in the surroundings or working conditions, which are unsanitary, hazardous,
or dangerous to employees, and who has authorization to take prompt corrective
measures to eliminate them.
Dry Soil means soil that does not exhibit visible signs of moisture content.
Duration of Exposure - the longer an excavation is open, the longer the other factors
have to work on causing it to collapse.
Excavation - any man-made cut, trench, or depression in an earth surface, formed
by earth removal.
Fissured means a soil material that has a tendency to break along definite planes
of fracture with little resistance, or a material that exhibits open cracks, such as
tension cracks, in an exposed surface.
Granular Soil means gravel, sand or silt, (coarse grained soil) with little or no clay
content. Granular soil has no cohesive strength. Some moist granular soils exhibit
apparent cohesion. Granular soil cannot be molded when moist and crumbles easily
when dry.
Hazardous Atmosphere - an atmosphere which by reason of being explosive,
flammable, poisonous, corrosive, oxidizing, irritating, oxygen deficient, toxic, or
otherwise harmful, may cause death, illness, or injury.
Layered System means two or more distinctly different soil or rock types arranged
in layers. Micaceous seams or weakened planes in rock or shale are considered
layered.
J7.3
Moist Soil means a condition in which a soil looks and feels damp. Moist cohesive
soil can easily be shaped into a ball and rolled into small diameter threads before
crumbling. Moist granular soil that contains some cohesive material will exhibit signs
of cohesion between particles.
Plastic means a property of a soil, which allows the soil to be deformed or molded
without cracking, or appreciable volume change.
Protective System - a method of protecting employees from cave-ins, from material
that could fall or roll from an excavation, or from the collapse of adjacent structures.
Protective systems include support systems, sloping and benching systems, shield
systems, and other systems that provide necessary protection.
Saturated Soil means a soil in which the voids are filled with water. Saturation
does not require flow. Saturation, or near saturation, is necessary for the proper use
of instruments such as a pocket penetrometer or sheer vane.
Shield - a structure that is capable of withstanding the forces imposed on it by a
cave-in and thereby protects employees within the structure. Shields can be
permanent structures or can be designed to be portable and moved along as work
progresses. All shields must be in accordance with 29 CFR 1926.652(c)3 or (c)4.
Sloping - a method of protecting workers from cave-ins by excavating to form sides
of an excavation that are inclined away from the excavation to prevent cave-ins. The
angle of incline required to prevent a cave-in varies with differences such as soil
type, length of exposure, and application of surcharge loads.
Soil Classification System means a method of categorizing soil and rock deposits
in a hierarchy of Stable Rock, Type A, Type B, and Type C, in decreasing order of
stability. The categories are determined based on an analysis of the properties and
performance characteristics of the deposits and the environmental conditions of
exposure.
Stable Rock - natural solid mineral matter which can be excavated with vertical sides
and remain intact while exposed.
Submerged Soil means soil, which is underwater or is free seeping.
Surcharge Loads - generated by the weight of anything in proximity to the
excavation, push starts for a cave-in (anything up top pushing down). Common
surcharge loads:
weight of spoil pile
weight of nearby buildings, poles, pavement, or other structural objects.
weight of material and equipment
J7.4
Trench - a narrow excavation below the surface of the ground, less than 15 feet
wide, with a depth no greater than the width.
Type A Soil - is cohesive with an unconfined compressive strength of 1.5 tons per
square foot (tsf). Type A soils include clay, silty clay, sandy clay, clay loam, caliche,
hardpan, and sometimes-silty clay loam and sandy clay loam. No soil should be
classified as Type A if it is fissured; subject to vibration from traffic, pile driving, or
similar effects; previously disturbed; or part of a sloped, layered system where the
slope is four horizontal to one vertical or greater.
Type B Soil - is cohesive soil with an unconfined compressive strength greater than
.5 tsf but less than 1.5 tsf. Type B soils include granular cohesionless soils like
angular gravel, silt, silt loam, sandy loam, and sometimes silty clay loam and sandy
clay loam; previously disturbed soils that are not Type C; fissured soils and soils
subject to vibration that would otherwise be classified as Type A; dry rock that is not
stable; and material that is part of a sloped, layered system where the layers dip on
a slope less steep than four horizontal to one vertical.
Type C Soil - is cohesive soil with an unconfined compressive strength of .5 tsf or
less. Type C soils include granular soils such as gravel, sand, and loamy sand;
submerged soil; soil from which water is freely seeping; submerged rock that is not
stable; or material in a sloped, layered system where the layers dip into the
excavation at a slope of four horizontal to one vertical or steeper.
Unconfined Compressive Strength means the load per unit area at which a soil will
fail in compression. It can be determined by laboratory testing, or estimated in the
field using a pocket penetrometer, by thumb penetration tests, and other methods.
Undermining - undermining can be caused by such things as leaking, leaching,
caving or over-digging. Undermined walls can be very dangerous.
Vibration - a force that is present on construction sites and must be considered. The
vibrations caused by backhoes, dump trucks, compactors and traffic on job sites can
be substantial.
Wet Soil means soil that contains significantly more moisture than moist soil, but in
such a range of values that cohesive material will slump or will begin to flow when
vibrated. Granular material that would exhibit cohesive properties when moist will
lose those cohesive properties when wet.
Requirements
Before Excavating
Before anyone at this company begins excavating, we follow the steps below:
Contact the utility companies or property owners and ask the companies or
owners to find the exact location of the underground installations in the area.
J7.5
If the utility companies or owners do not respond within 24 hours or the period
established by law or ordinance, or if they cannot establish the location of the
utility lines, the excavation may proceed with caution only with the Client or
Owners approval. In this situation, employees shall be provided with
detection equipment or other safe and acceptable means to locate utility
installations. Some Clients may require a Utility Representative Present
during the excavation.
Remove or adequately support the following objects (i.e., trees, rocks, and
sidewalks) in the excavation area that could create a hazard to employees.
Using Appendix A to 29 CFR 1926, Subpart P, classify the type of soil and
rock deposits at the site as either stable rock, Type A, Type B, or Type C soil.
The soil classification is based on the results of at least one visual and at
least one manual analysis conducted by a competent person. Details of the
acceptable visual and manual analyses are to be found in Appendix A of 29
CFR 1926, Subpart P.
NOTE: Soil classification is not necessary if the excavation will be sloped to
an angle of one and one-half horizontal to one vertical or if shoring is used.
Have the competent person choose the appropriate method for protective
support systems, as necessary. See the Protective Support Systems section
for the procedures he/she used for selecting this system.
Protective Support Systems
The company protects each employee in an excavation from cave-ins during an
excavation by an adequate protective system designed in accordance with OSHA
standards. Protective system options include proper sloping or benching of the sides
of the excavation; supporting the sides of the excavation with timber shoring or
aluminum hydraulic shoring; or placing a shield between the side of the excavation
and the work area. Moreno Group LLC and Subsidiaries has the following Standard
Operating Procedures (SOP) regarding protective support systems for excavations,
in accordance with safe practices and procedures and OSHA excavation
regulations:
If the excavation is made entirely of stable rock, then no protective
system is necessary or used unless the Competent Person or the
Client requires added safeguards.
If the excavation is less than 5 feet in depth (provided there is no
indication of a potential cave-in), then no protective system is
necessary or used.
If the excavation is less than or equal to 20 feet in depth, then a
competent person shall choose the most practical design approach
(that meets required performance criteria) for the particular
J7.6
Stable Rock
Type A
Type B
Type C
In Type A soil, simple slope excavations which are open 24 hours or less
(short term) and which are 12 feet high or less in depth may have a
maximum allowable slope of 1/2 horizontal to 1 vertical.
In Type A soil, excavations over 8 feet but less than 12 feet in depth with
unsupported vertically sided lower portions must have a maximum
allowable slope of 1H:1V and a maximum vertical side of 3.5 feet.
slope of 3/4 H:1V. The support or shield system must extend at least 18
inches above the top of the vertical side.
-
In Type B soil, all excavations 20 feet or less which have vertically sided
lower portions shall be shielded or supported to a height at least 18 inches
above the top of the vertical side. The excavation shall have a maximum
allowable slope of 1H:1V.
In Type C soil, all excavations 20 feet or less which have vertically sided
lower portions shall be shielded or supported to a height at least 18 inches
above the top of the vertical side. The excavation shall have a maximum
allowable slope of 1-1/2 H:1V.
The competent person chooses the best option for sloping for the job at hand.
Benching
When benching is used to protect against cave-ins, these options can be chosen for
designing benching systems:
Use Appendices A and B of 29 CFR 1926, Subpart P to determine the
maximum allowable slope (also, see table in Sloping section) and allowable
configurations for benching systems. The soil type must be determined in
order to use this option.
Use other tabulated data approved by a registered professional engineer.
Have an engineer design and approve the system to be used.
There are a number of exceptions or special cases to these general benching
guidelines, which should be utilized by your company if the conditions meet the
exception's requirements. The exceptions and conditions are outlined below:
J7.8
In Type A soil, excavations over 8 feet but less than 12 feet in depth
with unsupported vertically sided lower portions must have a maximum
allowable slope of 1H:1V and a maximum vertical side of 3.5 feet.
The competent person chooses the best option for sloping for the job at hand.
Support Systems, Shield Systems, and Other Protective Systems
Timber Shoring
When trenches do not exceed 20 feet, timber shoring according to OSHA
design specifications may be used. Designs for timber shoring in trenches for
company work sites are determined by the competent person using the
following method(s):
NOTE: The specifications do not apply in every situation experienced in the field;
the data were developed to apply to most common trenching situations. If the
specifications do not apply to the situation encountered in the field, the
competent person will make a determination of what approach to use to allow
safe protective support of the excavation.
Use the manufacturer's tabulated data and design in accordance with the
manufacturer's specifications, recommendations, and limitations. Deviations
from the manufacturer's specifications, recommendations, or limitations are
only allowed upon written approval of the manufacturer, which must be
obtained by the competent person prior to implementation. The written
approval is kept at the job site during construction of the protective system.
NOTE: Before using the OSHA data, the soil type must be determined.
Shielding
Determined by the competent person, designs for shielding are based upon the
following method(s):
Here are your options found under 29 CFR 1926.652(c):
J7.10
The competent person inspects the excavation and the adjacent areas on a
daily basis for possible cave-ins, failure of protective systems and equipment,
hazardous atmospheres, or other hazardous conditions. Inspections are also
required after the occurrence of any natural (i.e. rain) or man-made events (
i.e. blasting) that could increase the potential for hazards (see Attachment 1)
Employees may not begin work until after being informed by the competent
person that these inspections are complete.
A warning system (i.e. flag person, barricades, stop logs etc.) is used to alert
operators of mobile equipment and other employees at the work site of the
edge of an excavation.
Employees are not permitted under loads that are handled by lifting or digging
equipment. Employees are not allowed to work in the excavation above other
employees unless the lower level employees are adequately protected.
Sufficient means (i.e. ladders, stairway, ramp etc.) for exiting excavations 4
feet deep or more are provided and are within 25 feet of lateral travel for
employees.
Training
Training in excavating, trenching and shoring hazards and safeguards is required for
all, new or existing, employees who are involved in these activities. Employees who
have not been trained in the hazards and safeguards are not allowed to perform
tasks or jobs involving these activities. Initial training and periodic refresher training
is required and must include the following:
The requirements of this Policy-Procedure
Regulatory requirements
The proper use of excavating, trenching and shoring equipment
Care and storage of the equipment
The hazards and safeguards of excavating, trenching and shoring
activities
Training requirements for the First Line Supervisors or designees who are to be
designated as Competent personnel. These are the people who may inspect
excavations and may complete the Excavation Hazard Assessment Checklist.
Competent persons must receive specific training as required in the OSHA
Standard. This type of training is available from approved training organizations
identified by the SH&E Department. The SH&E Department shall maintain all
training documentation. Recorded information must include trainees name, date,
and trainers name or names and will be maintained.
Inspection Procedures
The competent person inspects excavations daily and during poor weather. Our
inspection checklist is located in Attachment 1.
J7.12
J7.13
J7.14
Attachment 1
J7.15
A1
Are employees protected from loose material that could fall into the
trench?
Are walkways provided when employees or equipment are required
to cross over excavations?
A2
A3
Are walkways that are six feet or more above lower levels of
excavations equipped with guardrails?
A4
Are employees provided with and are they required to wear proper
safety equipment?
A5
A6
A7
A8
A9
A10
A11
YES NO N/A
REMARKS:
ENTRANCE/EXIT PRECAUTIONS
B1
B2
YES NO N/A
REMARKS:
J7.15.a.1
C
C1
C2
COMPETENT PERSON
YES NO N/A
Does a competent person inspect the trench at the beginning of
each day and throughout the day as needed?
Is the trench inspected by a competent person following any
amount of rain?
REMARKS:
UTILITY INVOLVEMENT
D
D1
D2
YES NO N/A
REMARKS:
WATER ACCUMULATION
E
E1
E2
E3
REMARKS:
J7.15.a.2
YES NO N/A
F
F1
F2
F3
YES NO N/A
REMARKS:
HAZARDOUS ATMOSPHERES
G
G1
G2
YES NO N/A
REMARKS:
H
H1
H2
YES NO N/A
REMARKS:
I
I1
I2
I3
I4
I5
I6
I7
YES NO N/A
SHORING AND SHIELDING SYSTEMS
Are employees protected from cave-ins when entering and exiting a
shield?
Are protective support systems installed in a manner that protects
employees?
REMARKS:
J7.15.a.3
Fall Protection
Page: 1 of 15
Original: 01/01/2001
Revised: 10/01/2009
Fall Protection
Purpose
To establish protective controls for personnel working at elevated heights that will
prevent or minimize injury or death resulting from falls from elevated work locations.
Scope
This procedure establishes minimum requirements for working at unguarded
elevated work locations that are six (6) feet or more above floor or grade level. This
procedure applies to all Moreno Group LLC and Subsidiaries employees and subcontractors. It covers activities such as, but not limited to work in or on:
Pipe racks
Unguarded scaffolding
Suspended scaffolds
Tank tops
Process structures without guarded work platforms
Ladders
Work on + 10 Level offshore
Responsibilities
The Facility Manager / Offshore Manager or Designee is responsible for:
Understanding and complying with this procedure.
Evaluating the potential elevated work hazards at Moreno Group LLC and
Subsidiaries facilities / sites, qualifying the level of risk of each job and
establishing the required safeguards.
Re-evaluating the potential elevated work hazards when changes in work
areas may affect the safeguards required.
Monitoring work areas for compliance with this procedure and required
safeguards.
J8.1
J8.3
Guardrail system means a barrier erected to prevent employees from falling to lower
levels.
Lanyard A flexible line of rope, wire rope, or straps which generally has a
connector at each end for connecting the body harness to a deceleration device,
lifeline or anchorage.
Y Lanyard Two lanyards sharing a common shock absorbing device.
Leading Edge The edge of a floor, roof or formwork for a floor or other walking /
working surface (such as the deck), which changes location as additional floor, roof,
decking or formwork sections are placed, formed or constructed to be an
unprotected side and edge during periods when it is not actively and continuously
under construction.
Lifeline A component consisting of a flexible line for connection to an anchorage at
one end to hang vertically (vertical lifeline) or for connection to anchorages at both
ends to stretch horizontally (horizontal lifeline) and which serves as a means for
connecting other components of a personal fall arrest system to the anchorage.
Personal Fall Arrest System A system used to arrest an employee in a fall from a
working level. It consists of an anchorage, connectors, and a body harness which
may include a lanyard, deceleration device, lifeline or suitable combinations of these.
Qualified Person A person with a recognized degree or professional certificate and
with extensive knowledge, training, and experience in the fall protection and rescue
field who is capable of designing, analyzing, evaluating and specifying fall protection
and rescue systems to the extent required by the standard.
Rope Grab A deceleration device that travels on a lifeline and automatically by
friction, engages the lifeline and locks so as to arrest the fall of an employee. A rope
grab usually employs the principle of inertial locking, cam/level locking or both.
Safety Monitoring A safety system in which a competent person is responsible for
recognizing and warning employees of fall hazards.
Self-Retracting Lifeline/Lanyard A deceleration device containing a drum-wound
line, which can be slowly extracted from or retracted onto, the drum under slight
tension during normal employee movement and which after onset of a fall,
automatically locks the drum and arrests the fall.
Unprotected sides and edges means any side or edge (except at entrances to points
of access) of a walking / working surface, e.g., floor, roof, ramp, or runway where
there is no wall or guardrail system at least 39 inches (1.0 m) high
Walking / working surface means any surface, whether horizontal or vertical on
which an employee walks or works, including, but not limited to, floors, roofs, ramps,
bridges, runways, formwork and concrete reinforcing steel but not including ladders,
vehicles, or trailers, on which employees must be located in order to perform their
job duties.
J8.4
Requirements
This policy provides for continuous fall protection, when the possibility of a fall of 6
feet or greater exists. This may occur when work activities include traversing,
climbing, descending, etc. The First Line Supervisor shall be responsible for
recognizing fall hazards, communicate and monitor the hazard. Fall Hazards include
but not limited to, uneven surfaces, obstacles or clutter, elevated work areas,
inadequate handrails, inadequate barricades around a deck opening or edge,
improper climbing equipment, or fall protection equipment failure.
Fall prevention incorporates methods and practices that eliminate the possibility of a
fall. Wherever possible, eliminating the possibility of a fall through design changes
or a change in work procedures is preferred. Engineering out the hazards during
design of a work location, or modification to an area can eliminate the fall hazard
entirely. Where design modifications are not practical, or cannot totally eliminate the
hazards, traditional fall protection equipment such as handrails and guardrails is the
most effective risk reduction measure. Where traditional fall protection is not
possible, fall restraint and personal fall arrest systems shall be required.
When a Personal Fall Arrest System is utilized for fall protection, it must meet the
arresting force identified in the equipment section of this procedure and installed in
such a manner to prevent the employee from free falling more than 6 feet or contact
the lower level.
Equipment
A full body harness is required to properly distribute fall arrest forces to
minimize potential injury to the body in the event of a fall. The maximum
arresting force on an employee shall be limited to 1,800 lbs. The harness
must be made of polyester material, and be ANSI Z359.1 approved.
Harnesses shall be capable of supporting 5,000 lbs.
Y lanyards a maximum of 6 feet in length are required. Lanyards must be
ANSI Z359.1 approved. Lanyards must have a shock absorbing device
integral to them. Shock absorbers shall allow for a maximum deceleration
distance of 3.5 feet, and limit fall arrest forces to 900 lbs. All snap hooks
integral to lanyards shall be of the self-locking/self-closing design, which
meets ANSI Z359.1-2007. Lanyards shall be capable of supporting 5,000 lbs.
Lanyards shall be tied off to a suitable anchor point 100% of the time and also
during travel.
Anchor Point
An anchor point is a secure point of attachment for lanyards, lifelines, or other
components of a personal fall protection system. Anchor points shall be
capable of supporting 5,000 lbs. per employee attached, or shall be designed
with a safety factor of at least two by a qualified person. An anchor point
should be as directly overhead as possible, or attachment to the anchor point
should be chosen as to not allow a free fall of greater than 6 feet. In cases
where the anchor point is lower than the attachment point of the harness, a
J8.5
shorter lanyard or other fall arrest device (i.e. Retractable lifeline) should be
used. Handrails, barricades, tubing, cable trays, small diameter piping (i.e. 2
O.D. or less) shall not be used as an anchor point.
Additional Fall Protection
Horizontal Lifeline
Horizontal lifelines must be of a designed system (i.e. pre engineered system)
and installed under the supervision of a competent person. A Qualified
Person will design and approve the installation and use of all horizontal
lifeline systems, whether permanent or temporary. Because forces on the
anchorage points at each end of the horizontal lifeline can be much greater
than those on a vertical plane, only engineered systems may be used.
Horizontal lifelines can be rated for one or more persons depending on the
certification by the Qualified Person and must maintain a safety factor of at
least two. (1926.502 (d)(8)). Refer to 1926 subpart M, appendix C for
guidelines.
Vertical Lifeline
When vertical lifelines are used, each employee shall be attached to a
separate lifeline. Components of the vertical lifeline system shall be capable
of supporting 5,000 lbs. The attachment point of the fall arrestor shall be at
the dorsal dee-ring of the harness. When permanently installed ladder
climbing systems are used, the fall arrestor shall be attached at the chest
dee-ring of the harness.
Self Retracting Lanyard (SRL)
SRLs shall be installed using ANSI Z359.1 approved connectors (i.e.
carabineers or anchor pads/straps), to an anchor point capable of supporting
5,000 lbs. The attachment point of the SRL shall be at the dorsal dee-ring of
the harness. Users of SRLs shall not connect the snap hook of their lanyard
to the snap hook of a SRL. SRLs should be used when the potential free fall
distance is greater than 6 feet, or when the height of the walking/working
surface is less than 12 feet from ground level. ( A shorter lanyard may also be
used in the above situation.)
Inspection
Personal fall arrest systems shall be inspected prior to each use for wear, damage,
or other deterioration, and defective components shall be removed from service. All
systems and components involved in a fall shall be removed from service, tagged
Out of Service and turned into the SH&E Department.
Fall Protection shall have documented inspections on an Offshore Tool House
Checklist prior to going offshore by a Competent Person. While offshore, fall
protection documented inspections shall be performed utilizing the Offshore Tool
House Checklist monthly. For onshore locations, a Competent Person will perform
documented inspections prior to fall protection being issued and quarterly utilizing
the inspection checklist in Attachment 2 unless a more stringent documented
inspection is being utilized per tool room requirements.
J8.6
J8.7
Climbing
Tools and other materials shall not be carried by hand while climbing a
ladder.
Special precautions shall be taken when wet or other slippery conditions
exist.
Vertical beams shall not be climbed.
When climbing stairs, one hand shall be free to use the handrails.
Climbing on equipment such as pumps, exchangers, valve hand wheels,
transformers, electric motors, hand rails, structures, or any other facilities not
designed for climbing should be avoided. Climbing on conduit, cable trays, or
other equipment not capable of supporting the weight of a person is
prohibited.
Climbing on a ladder while another person is above or on the same section of
the ladder is prohibited.
When working from a ladder, the ladder shall be secure at both ends and fall
protection shall be utilized above 6 or in close proximity of a handrail where
there is potential for an individual to fall over the handrail.
When climbing a ladder over 24 feet in height, fall protection tie off system
shall be utilized.
Adequate support should be available when walking in pipe bands to provide
a safe walking/working surface without causing damage to the piping,
insulation or heat tracing.
Personal fall arrest systems must be used and anchored to a designated
anchor point when using, traveling on or working from mobile work platforms
such as:
Spiders,
Manlifts,
Scissor-lifts and/or
Crane baskets
Working over Water
When offshore working over water, where there are potential fall hazards,
such as and not limited to the following:
o Plus 10 level when no guardrails are present,
J8.8
o Boat landing or
o Working over the side of a platform
A fall arrest system and a USCG approved life jacket / work vest shall utilized.
The fall arrest system shall be secured to proper anchor points located above
the worker.
Scaffold Erection
During scaffold erection, a fall arrest system will be utilized. The preferred
method of tie-off shall be a structural member anchor point with an attached
SRL. In those cases, where an anchor point is unavailable above the
scaffolding location and a SRL can not be utilized, scaffold builders shall tie
off to the vertical scaffold member rosettes.
Lanyards and Anchor Points
When not in use, lanyards should be attached back to the harness in such a
way as to not present a tripping hazard. The ends of lanyards should not be
dragged on the ground.
Lanyards should be attached to the best possible anchor point (one that is
capable of supporting the forces of a fall), directly above the employee. The
anchor point should not be chosen if connecting to it presents a fall hazard.
Information concerning anchor point requirements should be obtained from
the client representative.
Anchor points shall be at least as high as the attachment point of the harness
in order to comply with 1926 M.
Lanyards shall be protected from cuts or abrasions. When a direct snap hook
to anchorage connection cannot be achieved, an anchorage connector should
be used.
Snap hooks should always be fixed to an anchorage as to not allow a side
load on the hook.
Knots shall not be tied in lanyards.
The snap hooks of a y lanyard shall not be connected to each other.
Lanyard snap hooks can not be connected back to the lanyard webbing
unless a lanyard is designed with tie-back features.
Same Level Fall Protection
Good housekeeping is the key to the prevention of same level falls
J8.9
Usable and waste material shall be stored out of walking / working surfaces
and shall not congest a work area
Surfaces shall be kept free of slipping hazards
Floor holes and openings shall be covered as not to create tripping hazards.
Hole covers must be capable of supporting at least twice the maximum load
that may be imposed on them. Covers must be secured and marked HOLE
or COVER.
Materials shall not be allowed to collect around work tables, desks, threading
machines, etc.
Leading Edges
Protection
Adequate barricades must be erected in such a manner as to restrict access
to the area by all personnel except those required to work in the area. The
barricade shall have a toprail that is 42 inches plus or minus 3 inches above
the walking/working level. The midrail shall be installed at a height midway
between the top and the walking/working level. In some situations a toeboard
may be required to be installed.
Access
In areas where the leading edge is left unguarded, use control lines to limit
access to the leading edge.
This control line must extend along the entire length of the exposed edge
and be approximately parallel to it.
Must be sufficient strength to support a person who may inadvertently
come into contact with it and have a minimum breaking strength of 200
pounds.
Be no less than 10 feet or no more than 15 feet from the edge.
Rigged in such a way that its lowest point is no less than 39 inches from
the walking surface and no more than 45 inches at its highest point.
Safety Monitor
When control lines are not utilized to protect leading edges a safety monitor
shall be posted.
Safety Monitor shall be competent to recognize fall hazards.
Safety Monitor shall warn the employee when it appears that the
employee is unaware of a fall hazard or is acting in an unsafe manner.
J8.10
and approved by a qualified person. This plan shall be implemented and maintained
onsite per section 1926.502(K).
Rescue Plan
(see Attachment 1)
Post Rescue Techniques
After a person has been promptly rescued the following post rescue techniques
need to be followed:
Communicate with the person and establish the level of consciousness and
evaluate injuries.
Continuously monitor the person.
If emergency medical personnel are onsite, ensure they are contacted to
assist in any medical needs.
Ensure the person remains in a sitting or kneeling position for approximately
45 60 minutes following the rescue.
All employees need to be medically evaluated at a preferred medical clinic
following a fall, even if there appears to be no injury to the individual.
Training
Any employee who might be exposed to fall hazards shall be trained by a competent
person in the following areas:
The nature of fall hazards in the work area.
The correct procedures for erecting, maintaining, disassembling, and
inspecting the fall protection systems to be used.
The use, operation and inspection of personal fall arrest systems and rescue
equipment.
The standards contained in subpart M.
All employees identified as Supervisors shall be trained to the Fall Protection
Competent Person level.
Certification of Training
Fall protection training shall be verified by preparing a written certification
record.
J8.12
The record shall contain the name or other identity of the employee trained,
the date, and the signature of the person who conducted the training.
Retraining
Retraining is necessary when it is believed that an employee has not
understood the training requirements.
Retraining is necessary when changes in the work place render previous
training obsolete.
Retraining is necessary when changes or additions in the types of fall
protection equipment to be used render previous training obsolete.
This fall protection policy was written as a minimum requirement to meet the criteria
of 29 CFR 1926 Subpart M. Compliance with this policy is in the best interest of
Moreno Group LLC and Subsidiaries and its clients. Any efforts to exceed the
requirements of this policy are encouraged, and in some cases mandatory as
required by Moreno Group LLC and Subsidiaries clients.
Any incident involving fall protection shall be reported and investigated per Moreno
Group LLC and Subsidiaries policies.
J8.13
Attachment 1
J8.14
Rescue Plan
Fall Protection Rescue Procedure
This procedure was written as the standard rescue procedure for a fallen
Moreno Group LLC and Subsidiaries employee. Deviation from this procedure
may at times be necessary due to the nature of the work environment and
other conditions present.
It is recommended that employees practice this procedure in a controlled
environment at regular intervals before being in an actual situation.
Any questions regarding this procedure should be directed to the Moreno
Group LLC and Subsidiaries SH&E Department.
Responsibilities and Procedures
It is the responsibility of the Moreno Group LLC and Subsidiaries
Management to insure that all employees are trained in the proper use of the
rescue equipment to be used by Moreno Group LLC and Subsidiaries.
It is the responsibility of Moreno Group LLC and Subsidiaries Management to
appropriate the funds to insure that the necessary rescue equipment is made
available at each job site.
It is the responsibility of all effected Moreno Group LLC and Subsidiaries
employees to insure that rescue equipment is used only for the purpose of
RESCUE.
Scope
(d) (20), which states that the employer shall provide for the prompt rescue of
employees in the event of a fall. Due to the nature of the work performed by
Moreno Group LLC and Subsidiaries, the company has allowed for the safest
and most efficient method of rescue.
Definitions
Aerial Lift - A mobile aerial work platform
Anchorage (anchor point) - A secure point of attachment.
Anchorage Connector - A device used to attach equipment components to an
anchor point.
Connector (Carabineer) - A device used to couple parts or components of a
system together.
J8.14.a.1
J8.14.a.2
J8.14.a.3
Equipment Needed
MSA Rescue Pole, Block / Tackle,
Remote Hook, Pole Adapter
Inspected By
Rescue Team
___________________________________
___________________________________
___________________________________
___________________________________
Lower the remote hook to the fallen worker's D-ring. Once engaged, pull in an upward motion to lock the
remote hook into place.
Begin raising the fallen worker by pulling on the free end of the rope on the block and tackle.
10
Steps
1
2
3
4
5
Once the fallen worker can be physically reached, tie the free end of the rope to the nearest structure. (If more
than one worker is involved in the process, this step can be eliminated by havng the other worker hold tension
on the rope while the fallen worker is pulled to safety.
Detailed Steps of Rescue Plan for Web Device Rescue System
Remove pole and rope from stowage bag. Release hitch in rope at rope block.
Loosen pole lock nut (above label).
Pull slack in rope through blocks and extend pole to desired length (up to 15 ")
Tighten pole lock nut. Unhook carabiner from pole handle strap.
7
8
With a firm grip on the pole and rope, extend the hook to the victim's D-ring and engage by pulling back on the
pole. Lay the pole aside in a secure place.
With the rescue hook and anchor sling atached, begin hoisting the victim. It may take more than one rescuer
to hoist the victim. As an added precaution, the rope should be tied off to a suitable anchor point.
Steps
1
2
3
4
Assigned To
Secure anchor sling (choke or basket) around a suitable anchor point and attach caribiner / block. The anchor
point should be overhead and directly above the fallen worker.
As the pole is extended, hold the pole and rope so the at the rescue hook does not release prematurely. If the
hook should inadvertently release, reattach by opening the hook latch and place in bracket.
Assigned To
Spider Recue
Assigned To
When job is complete, all equipment used in the fall needs to be taken out of service
and turned into the SH&E Department.
J8.14.a.4
Attachment 2
J8.15
DII Harness /
Lanyard #
Inspection
Date
Supervisor
Competent Person
Inspection Criteria: Web Device product with legible identification numbers? Webbing: No cuts, fraying, burns, stitching condition, chemical exposure?
Buckles: Deformed, corrosion, rust, chemical exposure, stitching? Snaps: Gates work freely, double lock works, deformed, corrosion, rust, chemical exposure?
J8.15.a.1
Page: 1 of 7
Original: 01/01/2001
Revised: 05/01/2008
J9.1
J9.2
containers at all times to eliminate the possibility of static sparks when refueling.
Any motorized equipment must be turned off before it is refueled.
Employees shall not smoke in close proximity (i.e. within 35 feet) to flammable
liquids or gases either on Company property or elsewhere.
In general, open burning is not recommended and may be done only where
permitted by law. During winter months, no fires are allowed on the job site for
personal warmth unless approved by facility management.
Bulk storage areas for flammable fuels and liquids must be located at least 20 feet
from any building and free from weeds, debris and other combustible materials.
The grading around a flammable liquid storage area should divert possible spills
away from buildings or other exposures. A curb or dike may also be required.
Small quantities of flammable liquids used on the job must be stored in UL Approved
and properly labeled safety cans.
NO SMOKING signs must be posted at the perimeter of bulk fuel storage areas, refueling areas and locations where flammable liquids are transferred or used.
Inside storage of flammable and combustible liquids must be done using approved
storage cabinets and must comply with OSHA Standard 1910.106 Flammable and
Combustible Liquids or other applicable regulations.
Portable Fire Extinguishers
Only fire extinguishers approved by Factory Mutual (FM), Underwriters Lab (UL), the
U.S. Coast Guard (USCG) or other nationally recognized testing lab (NRTL) shall be
used and they must be readily and safely accessible at all times. No extinguishers
using carbon tetrachloride or chlorobromoethane extinguishing agents are permitted.
Portable fire extinguishers must be maintained in fully charged and operable
condition at all times.
Fire extinguishers should be placed so that the maximum travel distances, unless
there are extremely hazardous conditions, do not exceed 75 feet for Class A
extinguishers or 50 feet for Class B.
Portable fire extinguishers must be placed at strategic locations throughout the
facility. At least one portable fire extinguisher with a minimum rating of 2A should be
provided for each 3,000 square feet of protected area.
One or more portable fire extinguishers with a minimum rating of 2A should be
located adjacent to any stairway.
At least one portable fire extinguisher with a minimum rating of 20B should be kept
readily accessible to areas where flammable gases or liquids are stored or handled.
J9.4
Fire extinguishers must be provided and maintained on all owned or leased mobile
equipment.
Fire extinguishers shall be visually inspected monthly and documented.
Inspection and Maintenance
Fire Extinguishers
All portable fire extinguishers must be hydrostatically tested at appropriate intervals.
Portable fire extinguishers must have an annual maintenance check. The annual
maintenance date should be recorded and the record retained for one year after the
last entry or the life of the extinguisher, whichever is less. Only qualified persons
shall make these inspections.
Inspection of Fixed and Portable Fire Suppression Equipment
Monthly, documented inspections should be made of all portable fire suppression
equipment to ensure the equipment is accessible and ready for immediate use.
All portable fire suppression equipment should be given a thorough documented
maintenance check by qualified service personnel at least annually.
Use
Detecting and extinguishing a fire in its incipient stage is critical. Failure to do so
may result in a much larger, more serious fire with a greater potential for personnel
injuries and property damage. All employees responding to fires will be trained in the
care, use and limitations of portable fire extinguishers. They will be expected to
report and respond to fires in the incipient stages in their areas.
Whenever
possible, fire fighting will be done using hand held portable fire extinguishers. Fires
beyond the incipient stage will be handled by the local fire department.
General Guidelines for Responding to Small Fires in the Incipient Stages are as
Follows:
Immediately call for help. Alert personnel in the area. Never try to extinguish a fire
without first summoning help.
If it is safe to do so, try to extinguish the fire using portable fire extinguishers. If it is
not practical or possible, keep personnel out of the area until help arrives.
NOTE: If a fire is being fueled by a flammable liquid or gas, shut off the fuel supply
before trying to extinguish the fire. Failure to do so might result in the spread of a
gas or vapor cloud, which would travel a considerable distance before reaching a
source of ignition.
Try to limit the spread of fire by cooling or removing adjacent flammable or
combustible materials.
J9.5
Direct emergency response personnel to the area and assist them to the extent of
your training.
Extinguishing Methods and Agents include the following:
Class "A" Fires (Cloth, wood, paper, etc.). Water is the best-extinguishing agent for
Class "A" fires. Dry chemical extinguishers containing an ABC multi-purpose agent
will also put out Class "A" fires.
Class "B" Fires (Flammable and Combustible Liquids and Gases). ABC or BC dry
chemical is the best agent for Class B fires. CO2 can be used in some cases but
may be ineffective in outside windy locations. Foam extinguishes may be effective
on small spill or pools fires of flammable or combustible liquids.
Fires involving flammable gases should not be extinguished until the fuel feeding the
fire is shut off. Failure to do so may result in a flammable gas or vapor cloud
traveling a considerable distance to a source of ignition. Water spray and fog can be
used to cool adjacent equipment and protect personnel. Once the fuel has been shut
off, any remaining fire can be extinguished using a water spray or fog.
Class "C" fires involve energized electrical equipment. Only portable fire
extinguishers containing a nonconductive fire extinguishing agent such as dry
chemical, carbon dioxide or Halon should be used. The products of combustion of
electrical insulating materials are usually very toxic and should not be inhaled.
When responding to an electrical fire, every reasonable effort should be made to
shut off the electrical supply to the circuit or equipment. If unable to shut off the
electrical supply, call an electrician to do so. Once the electrical supply has been
turned off, it is safe to use water based extinguishing agents on the fire.
Class D fires involve burning metals such as magnesium and only Class D
extinguishers that contain dry powder should be used.
Carbon dioxide displaces oxygen and should not be used where the operator must
enter very confined spaces or enclosures without self contained breathing
equipment. Likewise, high concentrations of Halon 1211 can be harmful if inhaled.
Hot Work Permits for work in areas identified as fire potential hazards must be
obtained from facility management or designee.
Employee Alarm Systems
The employee alarm system / PA system shall provide warning for necessary
emergency as called for in the action Emergency Preparedness Plan , or for reaction
time for safe escape of employees from the workplace or the immediate work area
or both.
The employee alarm shall be capable of being perceived above ambient noise or
light levels by all employees in the affected portions of the workplace.
J9.6
The employee alarm shall be distinctive and recognizable as a signal to evacuate the
work area or to perform actions designated under the emergency action plan.
Moreno Group LLC and Subsidiaries Management or designee shall explain to each
employee the preferred means of reporting emergencies, such as manual pull box
alarms, public address systems, radio or telephones.
Training
All employees upon assignment to their initial assignment shall receive training to
educate them on the general principles of fire extinguisher use and hazards involved
in incipient stage fire fighting.
Employees shall attend an annual refresher training on the above mentioned topics.
Training Records shall contain the following:
Name of employee
Date of Training
Signature of Trainer
J9.7
Forklift Program
Page: 1 of 8
Original: 01/01/2001
Revised: 10/01/2009
Forklift Program
Purpose
The purpose of this procedure is intended to promote the safe operation of forklift
trucks in accordance with 29 CFR 1910.178.
Scope
Moreno Group LLC and Subsidiaries policy requires that all personnel operating
and/or performing maintenance of forklift trucks shall be properly trained in forklift
truck operations.
Responsibilities
The Facility / Site Manager or Designee is responsible for:
Assuring compliance with this procedure.
Evaluating mobile equipment needs for the facility / site, preparing detailed
purchase / rental specifications and providing sufficient equipment to support
the needs of Moreno Group LLC and Subsidiaries.
Assuring the equipment is operated and maintained in a safe manner and in
accordance with equipment manufacturers recommendations.
Assuring that equipment operators are properly trained and qualified to
operate specific machines.
Ensuring that no modifications or additions are made to equipment without
the manufacturers written approval.
Ensuring that all accident investigations, significant incidents, property
damage reports, and general information regarding mobile / motorized
equipment is communicated to applicable employees.
Informing all Contractors of this procedure during the project meeting and
ensure the Contractor follows the requirements of this procedure.
The First Line Supervisor / Offshore Superintendent is responsible for:
Understanding and enforcing the provisions of this procedure.
J10.1
J10.4
When the unattended forklift truck is left, load-engaging means shall be fully
lowered, controls shall be neutralized, power shall be shut off, and brakes set. The
wheels shall be blocked if the truck is parked on an incline.
When the forklift trucks operator is within 25 feet and still in view of the forklift truck,
the load engaging means shall be fully lowered, controls shall be neutralized and
brakes set.
The operator shall not allow anyone to pass or stand under the elevated portion of
the forklift truck (loaded or unloaded).
The lifting of personnel shall not be conducted unless an approved personnel lifting
device is attached to the forklift truck.
Grades shall be ascended or descended slowly and when the grade is in excess of
10% the loaded truck shall be driven with the load upgrade.
On all grades the load and load engaging means shall be tilted back if applicable,
and raised only enough to clear the road surface.
The operator shall not park or block fire exits or aisles, access to stairways, and/or
fire equipment with the forklift truck.
Dockboard shall be properly secured before being driven over. Dockboards or
bridgeplates shall be driven over carefully and slowly. The rated capacity shall not
be exceeded.
The operator shall avoid running over loose objects.
Maintenance
Any forklift truck not in a safe operating condition shall be removed from service.
All repairs shall be conducted by authorized personnel.
Any forklift truck that is overheating shall be removed from service until the cause of
the overheating has been eliminated.
The forklift truck shall be kept in clean condition (i.e. excess oil and grease.)
Forklift trucks in need of repair to the electrical system shall have the battery
disconnected prior to conducting the repair.
Fueling
Fuel tanks shall not be filled while engine is running.
Do not operate forklift trucks with leaks in the fuel system.
J10.5
Loading/Off Loading
Never exceed the allowable weight and load centers of the forklift truck.
allowable limits are indicated on the forklift truck nameplate.
The
Only stable or safely arranged loads shall be handled. Exercise caution when
handling off-center loads which cannot be centered. Long or high, including multiple
-tiered loads, which may affect capacity or stability, shall be adjusted.
No load that is not designed (must have two closed channel to receive the forks) to
be lifted by a forklift.
The engaging means shall be placed under load, the forks shall extend past the
load. The mast shall be carefully tilted backward to stabilize the load. Use extreme
care while tilting the load forward or backwards, especially multiple-tiered loads.
Elevating shall be prohibited while a load is tilted forward, except to pick up the load.
Tilting forward while a load is elevated is prohibited except when the load is in a
deposit position over a rack or stack.
When stacking or tiering, use only enough backward tilt to stabilize the load.
No loading or unloading of equipment and/or material is allowed after normal
working hours without Management's approval.
Delivery drivers shall be placed within the designated safe area during the loading
and offloading of their vehicles / trailers. Trailers that are not attached to a vehicle
shall be chocked prior to loading or offloading of the trailer.
Certification of Training
Upon completion of a Forklift Training (written and hands on examination), the
instructor shall certify employees by preparing a written certification record by
placing the individuals name on the companys approved Forklift Operator
Log.
The record shall contain the name or other identity of the employee trained,
the date of the training (classroom and hands on evaluation) and the
signature of the person who conducted the training.
Retraining
An evaluation of each forklift operators performance shall be conducted at
least once every 3 years
Retraining will be preformed if the forklift operator is involved in an incident
(i.e. Near Miss, Property Damage, etc.) involving the use of a forklift.
J10.6
J10.7
Attachment 1
J10.8
TRUCK #
VISUAL CHECKS:
N/A
1.
2.
3.
4.
5.
6.
OK
NEEDS
REPAIR
N/A
NEEDS
OK REPAIR
HORN
FUEL LEVEL
STEERING
RADIATOR LEVEL
SERVICE BRAKES
PARKING BRAKES
TILT CONTROLS
TIRE CONDITIONS
DRIVE TRANSMISSION
CONTROLS
ATTACHMENT OPERATIONAL
HEAD/TAIL LIGHTS
AMMETER OPERATING
WARNING LIGHTS/SIGNALS
BACK UP ALARM
FIRE EXTINGUISHER
No
REMARKS:
J10.8.a.1
TRUCK #
VISUAL CHECKS:
N/A
OK
NEEDS
REPAIR
N/A
NEEDS
OK REPAIR
HORN
FUEL LEVEL
STEERING
RADIATOR LEVEL
SERVICE BRAKES
PARKING BRAKES
TILT CONTROLS
TIRE CONDITIONS
DRIVE TRANSMISSION
CONTROLS
ATTACHMENT OPERATIONAL
HEAD/TAIL LIGHTS
AMMETER OPERATING
WARNING LIGHTS/SIGNALS
BACK UP ALARM
FIRE EXTINGUISHER
HOUR METER
7.
8.
9.
10.
11.
No
REMARKS:
J10.8.a.2
Line-Opening / Blinding
Procedure
Page: 1 of 6
Original: 01/01/2002
Revised: 01/01/2003
J11.1
Upon completion of the work, verifying that the work has been left in a
safe, clean condition and the authorized personnel have removed their
lockout / tagout devices from the system.
The Employee is responsible for:
Reviewing, understanding and signing the permit prior to beginning work.
If there is any question concerning the SH&E of the plan, all issue(s) must
be resolved prior to starting work.
Placing their personal locks and tags on all required locations.
Reviewing, approving, signing and following the tasks Job Safety and
Environmental Analysis (JSEA).
Inspecting all required Personal Protective Equipment, ensuring defective
personal protective equipment is not used and reporting any discrepancies
to the First Line Supervisor.
Identifying the location of the nearest safety shower and eye wash station
and checking its operation.
Treating any line or piece of equipment as full, under pressure or
containing product. Requiring that the following actions be taken for any
breaking activity:
o Assuring there is a free and clear escape route from the work
location.
o Using required safety equipment.
o Using containment for liquids and solids that may still be in the
system.
Following completion of the work, cleaning work area, removing their
locks, and notifying their First Line Supervisor that the work is complete.
Reporting unsafe conditions or plans to deviate from the JSEA.
Definitions
Blank / Blind Flange - the solid plate or cap which completely covers the bore of
a pipe, line, etc. The blank / blind must absolutely close the line, pipe, etc., must
be capable of withstanding the maximum upstream pressure and be fabricated
from compatible materials.
J11.2
Double Block and Bleed - two locked and tagged closed valves with a locked and
tagged open drain or vent between them.
Energy Isolating Device - a mechanical device that physically prevents the
transmission or release of energy including, but not limited to, the following: A
manually operated electrical circuit breaker, a disconnect switch; a manually
operated switch by which the conductors or a circuit can be disconnected from all
ungrounded supply conductors and, in addition, no pole can be operated
independently; a slide gate; a slip blind; a line valve; a block; and any similar
device used to block or isolate energy. The term does not include a push button,
selector switch or other control circuit type devices.
Equipment Owner - the owner, operator of the equipment.
Slip Blind - a metal disc with a short handle, which is used to block the flow of
material in a pipe. It is to be slipped between two flanges and bolted in place.
Requirements
When performing maintenance or repair to process equipment or piping or when
performing a confined space entry, the equipment must be isolated from all
energy sources and must be controlled. Isolation is a process of physically
closing or disconnecting or both, pipes, lines and energy sources from the
equipment where exposure may be present. Isolation may be accomplished by
several means but not limited to the following:
-
Blanking
Blinding
J11.3
Hard Hat
Face Shield
Tyvek Suits
Gloves
When available a nitrogen purge should be used to purge the hydrocarbon vapor
from a vessel or line.
J11.4
Inspect the area above, below and adjacent to the work area (at least 35 feet in
all directions) for any potential hazards, people, equipment or operations that
could adversely affect the work to be performed or could be adversely affected
by the work. Take the appropriate precautions (i.e., barricade the area, cover
equipment and cable trays, stop all hot work, etc.)
A Job Safety and Environmental Analysis (JSEA), Lockout / Tagout and the
Facilitys Permit systems shall be implemented prior to the beginning of the
blinding or line opening procedure.
Breaking of the Flanged Joint
Ensure all employees have the correct Personal Protective Equipment dictated
by the circumstances. When opening flanges suspected to contain toxic gases,
self-contained breathing apparatus or supplied air respirator with an egress bottle
is to be worn unless it has been definitely established through testing that no
toxic gases are present.
Ensure a containment system (i.e. bucket, drip pan, etc.) is placed underneath
the flange to capture any trapped liquid.
To remove flange bolting, the employee should loosen only one bolt at a time
starting with the bolt down and away from the workers, so any sudden release
will be directed away from any personnel. Note: Should any trapped liquid or
pressure is experienced, the task shall be shut down and the system shall be
reevaluated to ensure the system is properly isolated. Remove the entire flange
bolting except for a minimum of two (2), then loosen these bolts without
completely removing the nuts, and spread the flanges to install the blind.
Note: When vapors are present and cannot be eliminated, brass equipment (i.e.
hammers, wedges, etc.) shall be used to eliminate the potential for sparks to be
produced while opening the process equipment or line.
Installation of Blinds
The flanges should only be open a minimum length of time consistent with the
safe installation of the blind.
Blinds will be installed at the flange closest to the vessel, tank or equipment
under consideration.
When vessels or process equipment is interconnected in such a way that blinding
of each is not possible or practical, the combination is to be considered as one
vessel. The combination will be appropriately blinded and prepared as a unit.
J11.5
When it is necessary for personnel to climb onto the tops of fixed-roof storage
tanks to install blinds, scaffolding shall be used to minimize the likelihood that
personnel might step through a weak spot.
Blinds should be tagged with the location of the blind, the person installing the
blind, and the date the blind was installed.
Upon completion of the job, clean up the work area; notify your First Line
Supervisor, so any related permits may be cancelled.
J11.6
Permit to Work
Page: 1 of 12
Original: 01/01/2001
Revised: 10/01/2006
Permit to Work
Purpose
The purpose of a Permit to Work system is to reduce the risk of an incident or exposure
to a hazard during simultaneous operations within Dynamic Industries, Inc. facilities.
This procedure should assist in the coordination and minimization of hazards associated
with simultaneous operation within Dynamic Industries, Inc. facilities.
Scope
This procedure outlines provides a permitting system for simultaneous activities within
Dynamic Industries, Inc. facilities and outlines responsibilities, requirements and
authorization for this Permit to Work system. Below are examples of Simultaneous
operations covered by this system:
Testing of equipment with hydrocarbons and Hot Work
Sandblasting or Coatings Operations and other craft activities in the same
immediate area (i.e. same level of platform or module)
Hydrostatic Testing and other craft activities
Coordination of the commissioning of electrical components and the installation,
maintenance or servicing of electrical components.
X-ray activities outside designated areas
Note: Confined Space Entries will be performed and conducted in accordance with
Dynamic Industries, Inc. Confined Space Entry Safe Work Practice.
Responsibilities
The Facility / Site Manager or Designee is responsible for overall program
administration including:
Provide resources to fully implement this program.
The SH&E Department or designee (Authorized Permit to Work Issuer) is responsible
for:
Assessing the work area a long with the First Line Supervisor to ensure
proper controls are in place and a need of a Permit to Work, prior to the
issuing of a permit.
Confirm that all isolations are in place, tagged and where appropriate locked
The issuing of a Permit to Work at the jobsite to First Line Supervisors and
their crew for the covered activity.
J12.1
Discussing and verifying that all requirements are understood by the First
Line Supervisor and their crew performing the covered work activity.
Closing out of permit with First Line Supervisor
Training additional individuals to issue Permit to Work, if required by
Management
Maintaining a list of Authorized Individuals who can issue Permit to Work
Assess the effectiveness of the Permit to Work system and provide
assistance to Facility Management as needed.
Following safe practices while performing their covered work activities. This
includes:
Practicing good housekeeping
Wearing proper clothing / PPE including any necessary respiratory protection
Reading and following safeguards on Material Safety Data Sheets (MSDS) or
product labels as applicable
Posting warning signs or barricades as necessary
Using equipment per manufacturers instructions
Ensure equipment is properly isolated, tagged and locked out if required.
Following conditions specified on the Permit to Work.
Understanding and following the general and specific requirements outlined in
this procedure.
Signing the Permit to acknowledge acceptance of Permit requirements
Stopping Work and notifying their immediate Supervisor if conditions change with
their work activities or work environment.
Requirements
This Permit to Work system shall be implemented at Dynamic Industries, Inc. facility
anytime one of the following work activities is performed and can affect or expose
another work activity that is within its immediate work area.
Abrasive Blasting
Coating operations
Hot Work (only when hydrocarbons is introduced to the system or adjacent to
coatings operations)
Hydrostatic Testing
NDT Activities X-ray
Testing of Electrical Components
Abrasive Blasting / Coasting Operations
Anytime abrasive blasting / coating operations are being performed next to or adjacent
to other operations outside the designated blast area, a Permit to Work shall be
required. The only time a Permit to Work would be required within a designated
blasting area is if another work activity other than painting or blasting was being
performed.
J12.3
Precautions shall be taken to minimize the affects of this type of operations with others.
Blast screens shall be installed to minimize the affects on other operations prior to the
Permit to Work being issued to the First Line Supervisor. Addition to blast screens,
firewatch with gas detectors shall be required if hot work is being performed within 35
feet radius of the painting operations.
NOTE: Paint brushing operations is exempted from this requirement
Hot work
Hot work activities include welding, open flame cutting, gauging, grinding, mechanical
buffing or other spark producing activities.
Hot work activities shall require a Permit to Work during the following situations:
Being performed within 35 feet radius of a coatings operations (paint brushing
operations is exempted from this requirement)
Being performed on a platform, module or structure that contains hydrocarbons
within the system whether placed within the system for testing purposes or
permanently maintained within the system.
All precautions shall be taken to minimize the affects of hot work operations with others.
No Hot Work will be allowed within 10 feet radius of any system containing
hydrocarbons or coatings activities. Note: Consider the 10 feet radius is a vertical cone
that is 10 in diameter to help determine if any system falls within this requirement.
Slag, sparks or other burning materials shall be prevented from contacting equipment
which contains flammable in an area within 35 feet of the work or any level below where
sparks may reach. Metal shields, flame resistant guards or curtain may be used to
prevent contact if the equipment cannot be relocated from the work area.
Firewatch shall be required a condition of this Permit to Work. The Firewatch shall have
fire extinguishing equipment and a portable gas detection meter readily available and be
trained in their use. These individuals shall be on each level of the structure that the
hot work can affect.
They shall be familiar with procedures for initiating the emergency evacuation procedure
in the event of a fire. They shall only attempt to extinguish a fire when the fire is
obviously within the capacity of the equipment available. A fire watch shall be
maintained for 30 minutes after the completion of welding or cutting operations to detect
and extinguish smoldering fires.
Note: If the coating operations are completed prior to the welding operations, the
firewatch shall remain 30 minutes after the completion of the painting operations is
completed. The Permit to Work maybe closed at the completion of either one of these
activities, which ever is completed first.
J12.4
Hydrostatic Testing
All hydrostatic testing activities performed within Dynamic Industries, Inc. facilities shall
require a Permit to Work when simultaneous operations are occurring adjacent to the
hydrostatic test. Should a hydrostatic test be performed on a platform or any other type
of structure, then the simultaneous activities will be required to be shut down. No
simultaneous activities will be allowed on any platform or structure where hydrostatic
testing is being performed. If a system, is being testing affect two levels of the platform
or structure, then no activities maybe performed on these levels except for the
hydrostatic testing.
All hydrostatic tests shall follow the hydrostatic test procedures outlined by the
Hydrostatic Test Pack.
Barricades
Precautions shall be taken to ensure that hydrostatic testing is performed safely. The
area surrounding the hydrostatic test shall be cordon off with red Danger barricaded
tape. The distance in which will be cordon off will be determined by the First Line
Supervisor and Issuer of the Permit to Work.
Barricades shall be erected to prevent employees, visitors, equipment and vehicle traffic
from accidentally entering the hydrostatic testing work area.
No one shall enter the hydrostatic testing area unless is authorized by the First Line
Supervisor, has read and understood both the JSEA and Permit to Work.
Anyone entering the barricaded area without authorization shall be asked to
immediately leave the authorized area and the Facility Management or SH&E
Department shall be notified.
No one shall remove or modify the barricaded area without authorization from the First
Line Supervisor. Should this activity occur during night time hours, enough lighting
should be present to ensure the barricade is visible.
Warning signs shall be installed on barricades to appropriate communicate to others
within the area. The signs shall read Danger High Pressure Equipment, KEEP AWAY
Equipment
All equipment used for the hydrostatic testing shall be rated for the appropriate pressure
ratings for the test procedure including but not limited to existing piping and
connections.
All hoses are to be fully secured with tie-down devices capable of withstanding the
forces used in the test. All hoses shall have both safety pins and whip checks installed
on them to help prevent the possibility of them parting and whipping freely.
J12.5
All gauges shall be calibrated and applicable for the pressures to be used during the
hydrostatic test.
Pressure relief valves on the pump have been tested and capable of handling the
pressures needed for the test.
During the Test
Only those individuals directly involved with and who have signed the Permit to Work
shall be allowed in the barricaded area.
Those test involving high pressure, the systems test pressure shall be reached in
stages, allowing each stage to stabilized, then check for leaks.
Should a leak occur during the test, the test will be STOPPED and the system will be
depressured. Once the system has been fully depressured, employee(s) will be allowed
to investigate the reason for and/or correct any issue surrounding the leak.
Communication shall be established between all employees involved with the
hydrostatic test procedure. At a minimum, hand signals shall be used to help minimize
miscommunication during this procedure.
Non Destructive Testing (NDT) X-Ray
All NDT X-ray testing performed outside designated areas within Dynamic Industries,
Inc. facilities shall require a Permit to Work.
The barricade tape shall meet the requirements within Dynamic Industries, Inc.
Barricading procedures. Barricades shall be erected to prevent employees, visitors,
equipment and vehicle traffic from accidentally entering the regulated work area. To
utilize cones for barricades the Facility Managers approval is required. NDT Company
First Line Supervisor shall be responsible for calculating the safe distance for the public
exposure to this operation. The erecting the barricade shall be erected to the 2 mr/hr
time weight calculation within any hour.
Warning signs shall be installed on barricades to appropriate communicate to others the
hazards of this operations. The signage shall have the words Caution Radiation Area
Authorized Personnel Only that includes the 3 bladed radiation symbol.
No one shall enter the regulated area unless is authorized by the NDT Company First
Line Supervisor and has read and understood both the JSEA and Permit to Work.
Anyone entering the barricaded area without authorization shall be asked to
immediately leave the authorized area and the Facility Management or SH&E
Department shall be notified.
No one shall remove or modify the barricaded area without authorization from the NDT
Company First Line Supervisor. Should this activity occur during night time hours,
enough lighting should be present to ensure the barricade is visible.
J12.6
Barricades
Precautions shall be taken to ensure that electrical testing is performed safely. The
area surrounding the electrical test shall be cordon off with red Danger barricaded
tape. The distance which will be cordon off will be determined by the First Line
Supervisor and Issuer of the Permit to Work.
Barricades shall be erected to prevent employees, visitors, equipment and vehicle traffic
from accidentally entering the electrical testing work area.
No one shall enter the electrical testing area unless is authorized by the First Line
Supervisor, has read and understood both the JSEA and Permit to Work.
Anyone entering the barricaded area without authorization shall be asked to
immediately leave the authorized area and the Facility Management or SH&E
Department shall be notified.
No one shall remove or modify the barricaded area without authorization from the First
Line Supervisor. Should this activity occur during night time hours, enough lighting
should be present to ensure the barricade is visible.
Warning signs shall be installed on barricades to appropriate communicate to others
within the area. The signs shall read Danger High Voltage Equipment, KEEP AWAY
J12.7
Multiple Jobs
Multiple jobs are allowed at the discretion of the Authorized Permit to Work Issuer.
A given Permit may cover one job or a group of jobs in the same general area however,
separate Permits will be required for 3 or more simultaneous activities within the same
general area.
Each First Line Supervisor of the employees performing the simultaneous activities shall
sign as the Responsible Person on the Permit to Work.
Issue of Permit to Work
The First Line Supervisor shall be responsible for requesting a Permit to Work from the
SH&E Department prior to the start up of their task that may require this system to be
implemented.
The SH&E Department Representative shall initiate a Permit to Work System after
considering the following questions:
Identifies with the First Line Supervisor that the operation to be performed
creates simultaneous operations and requires a Permit to Work System to be
implemented. If yes, review the next question.
Identifies with the First Line Supervisor if the operations can be scheduled
differently to not create simultaneous operations. If the operations can not be
rescheduled, a Permit to Work System shall be initiated. . If supplementary
Permit (i.e. confined space) is required, the entry should be rescheduled where
the simultaneous operations can not affect the entry being performed safely.
The SH&E Department Representative shall initiate a Permit to Work by:
Verifying the job can be performed safely and that all necessary isolations (i.e.
lockout / tagout, screens, firewatch, etc.) are in place prior to;
Completing all sections of the Permit to Work and authorizing for the work to
proceed
The First Line Supervisor and his crew shall:
Reviewing, Understanding and Signing the Permit to Work
Discuss hazards and precautions with the SH&E Department Representative as
part of the task Job Safety and Environmental Analysis (JSEA)
When required, obtain, review, understand and sign any required supplementary
permit (i.e. Confined Space) that maybe required in addition to the Permit to
Work
Upon completion of the Permit to Work, the SH&E Representative shall provide the
original (top) copy of the Permit to Work to the First Line Supervisors to post at the
jobsite where the simultaneous operations is being preformed. The middle copy of the
Permit to Work shall remain open in the SH&E Department Office until the completion
J12.9
of the task or until the end of the shift (or extension). The bottom copy of the Permit to
Work shall remain in the Permit to Work Booklet.
Withdrawal of Permit to Work
Should there be a change in conditions, which introduces a new or identified hazard to
the permitted simultaneous operations or render stated precautions inadequate, the
employees and/or the First Line Supervisor shall STOP WORK and notify the SH&E
Representative.
If the scope of the jobs under the Permit to Work changes after it has been issued, the
employees and/or First Line Supervisor shall STOP WORK and notify the SH&E
Department. SH&E Department shall modify the Permit to Work to reflect the change(s)
in the scope of work. The change(s) may require the SH&E Department to close the
original Permit to Work and issue a new Permit to Work.
The Facility Management and/or the SH&E Department shall have the authority to
STOP any WORK and withdraw the Permit to Work at anytime.
Every person onsite has the right to discuss the withdrawal of a Permit to Work at
anytime with the Facility Management or SH&E Department.
Duration of Permit to Work
The normal period of validity for a Permit to Work is the duration of a shift (i.e. 12
hours). The SH&E Representative may extend the Permit to Work, if the simultaneous
operations is incomplete when the Permit expires for only two (2) additional hours,
provided the same employees and supervision is still performing the operations, there a
no additional hazards, and the precautions specified on the original Permit to Work shill
apply.
The extension of the Permit to Work can be provided by completing the Extension
Section of the Permit to Work. The extension must be initialed by both the SH&E
Representative and First Line Supervisors involved with the simultaneous operations.
By initialing the extension portion of this permit means that no changes within the job
scope, personnel involved within the task or hazards associated with the simultaneous
operations.
In the event of a Firewatchs gas detection meter alarm or any other emergency
requiring the stopping of the work under the Permit to Work, the First Line Supervisor
shall discuss the conditions with the SH&E Department prior to recommencing work.
Permit to Work Issuer or Recipient
Anytime additional employee(s) may arrive to the jobsite, this employee(s) shall review
with the First Line Supervisor the task JSEA and Permit to Work requirements. Upon
completion of this review, the employee(s) shall sign the Permit to Work and associated
JSEA to indicate they have reviewed and understands the requirements of both the
Permit to Work and job JSEA.
If a new Permit to Work Issuer (i.e. shift change, etc.) is present during the duration of
the Permit to Work, the new issuer shall countersign the original Permit to Work, after
J12.10
they have verified the permit and permit conditions are still being met and the permit is
still valid.
Completion of Simultaneous Operation
At completion a job or jobs that created the presents of simultaneous operations, the
First Line Supervisor(s) shall ensure that the jobsite is left in a safe manner and in an
appropriate level of housekeeping. The First Line Supervisor shall sign the completion
section of the Permit to Work and bring the signed Permit to Work back to the SH&E
Department office.
The SH&E Department shall attached the original Permit to Work with the middle copy,
which was posted in the office and filed for 1 year.
J12.11
Attachment 1
J12.12
Time: _____________________
This permit is valid from: Date: __________ Time: _______ To Date: __________ Time: _______
Gas Tests:
O2%: __________ LEL%: __________ N/A: __________
Extension (2 hrs only) To: Date: __________ Time: _______
Gas Tests:
O2%: __________ LEL%: __________ Supervisor:_____________
Signatures
Supervisor: _______________________
___________________________
SH&E:
________________________
MG&S,LLC PTW
_____________________
J12.12.a.1
J.12.12.a.2
.1
Personal Protective
Equipment
Page: 1 of 7
Original: 01/01/2002
Revised: 01/01/2010
J13.1
replacement
PPE,
per
our
replacement
PPE
procedure
Conferring with personnel reporting to him / her as to the hazards of a job and
the PPE required.
Obtaining special PPE when required for a specific job.
Monitoring the job and work area for compliance with PPE requirements and
condition of PPE.
Initiating the use of additional PPE as specified in permits.
The Employee is responsible for:
Complying with this procedure and using required PPE.
Conferring with supervision as to hazards involved and PPE requirements
associated with the job.
Inspecting PPE prior to each use for proper fit and maintaining PPE in a good
and clean condition.
Advising supervision of any suggestions to improve the use or selection of
PPE and alerting them to any problems concerning PPE.
J13.2
Requirements
Appropriate clothing shall be worn to provide adequate protection. Proper clothing
may vary from job to job. The following outlines general clothing requirements:
Loose clothing, neckties and jewelry shall not be worn while working around
moving machinery.
No jewelry, except for watches, shall be worn while performing any work
tasks outside of the office or living quarters. Examples of jewelry are, but not
limited to, rings, loop earrings, piercing (whether exposed or not) or
necklaces. Watches shall be removed when welding or working around any
electrical sources.
Shirts or blouses shall be worn at all times. Tank tops, fish net or sleeveless
shirts shall not be worn.
Shorts, short pants or cut offs shall not be worn.
Clothing that becomes saturated with flammable liquids or chemicals should
immediately withdraw to an area safe from fire hazards, change clothing and
take appropriate steps of decontamination.
Note: When specific protective clothing, equipment or barrier creams are required,
the supervisor will provide them.
Employees should inspect their PPE each day prior to use. Any defects or damage
that is identified by the employee supervisor shall be removed for service and
replaced.
Issuing of Personal Protective Equipment
Each employee shall receive the following required Personal Protective Equipment
at No Charge upon their successful completing of their New Employee Orientation /
SH&E Training:
Hard Hat
Safety Glasses
Respirator (Blasters and Painters)
Gloves (Rigging and Welding)
Work Vest (offshore employees)
Moreno Group LLC and Subsidiaries will replace the above mentioned Personal
Protective Equipment at No Charge to the employee, if the employee follows the
proper PPE replacement procedure. This procedure is as follows:
J13.3
The employee will be responsible for bring their damaged or worn PPE to their Yard
Superintendent, Offshore Superintendent or designee. Upon receiving the damaged
PPE, the issuing authority will be responsible for providing the replace PPE, at No
Charge, to their employee.
Should the employee not provide to the issuing authority at the time their PPE
replacement request, their damaged or worn PPE, the employee will be payroll
deducted for the replacement PPE.
Head Protection
Moreno Group LLC and Subsidiaries will furnish to all employees the appropriate
head protection (hard hats). All employees shall wear hard hats while on the job
location except offices, vehicles, helicopters, crew boats and other areas that may
be exempted by facility policy. Offshore welders will be required to wear a hard hat
while welding.
All hard hats shall meet ANSI Z89.1 Safety Requirements For Industrial Head
Protection. Hard hats shall not be worn which are made of metallic material.
Employees will be responsible for keeping their hard hats clean and in good repair
and shall not alter the hard hat by drilling, painting, cutting or carving. All damaged
hard hats shall be returned to the employees supervisor for replacement.
Hard hats will be provided upon hire and then every five years.
Ears
Appropriate hearing protection is provided by Moreno Group LLC and Subsidiaries.
Hearing protection shall be worn in all designated areas or area that are suspected
of excessive noises level because of an individual task being performed in that area.
Eye Protection / Face Protection
All employees and visitors must wear approved safety glasses at all times outside of
offices, vehicles, break rooms and tool rooms. Eye protection shall meet ANSI Z87.1
specifications.
Safety glasses will be provided upon hire and once a quarter there after.
Wearing of contact lenses is discouraged, although wearers of contact lenses shall
inform their First Line Supervisor or Superintendent that they are wearing contact
lenses so that proper emergency care can be given if necessary.
Contact lenses shall not be worn in places where there is a risk of liquid spray from
hydrocarbons, chemicals, H2S, paints, acids, caustics or liquid substances that can
burn or be corrosive to the eyes.
Employees who wear prescription glasses will be required to wear prescription
safety glasses with side shields at all Moreno Group LLC and Subsidiaries facilities
or client locations. The company will provide prescription safety glasses with
J13.4
permanent side shields to these employees, whose job requires safety glasses,
under the following guidelines:
The employee will be required to furnish, at his/her expense, a current eye
glass prescription.
The prescription shall not be older than 12 months old.
New employees will be required to purchase, at their expense, their
prescription safety glasses. However, upon completing 90 days of continuous
employment, the company will reimburse the employee for their prescription
safety glasses.
Employees will receive only one pair of clear-lens prescription safety glasses
per year. To receive more than one pair of prescription safety glasses, the
employee must receive approval from their First Line Supervisor or Offshore
Manager.
Note: Receipt indicating the cost of the prescription safety glasses will be required in
order for proper reimbursement.
Impact goggles or safety glasses shall be worn with a faceshield when engaging in
any activity that involves hazards to the unprotected eye or face from chipped or
flying particles. Examples are chipping, scrapping, buffing, grinding, burning, etc.
Chemical goggles shall be worn with a faceshield when employees are handling
open hazardous chemicals, liquids, powders, and vapors or when the Material
Safety Data Sheet (MSDS) of the product specifies this protection.
Hand Protection
Gloves shall be worn to minimize and/or eliminate the potential for injuries to hands
and/or the fingers. It is important to match the type of glove used to the mechanical
and contact hazards that may be encountered. Some examples, but are not limited
to, are tools, sharp objects or wire rope etc. Appropriate gloves shall be worn when
material handling, handling chemicals or hazardous materials. Impermeable gloves
should be selected to provide adequate protection against the liquid material being
handled. The Material Safety Data Sheet shall be referred to prior to handling the
material. Some examples of gloves are:
Welding Gloves for protection against hot material.
Latex Gloves for protection against Bloodborne Pathogens
Leather Gloves for material handling
Cotton Gloves for material handling
Nitrile for handling chemicals
J13.5
The employee shall be responsible for inspecting protective equipment prior to and
after use. The inspection should identify any cuts, tears or abrasions. If protective
equipment is found defective the employee shall properly dispose of the items. The
employee is also responsible for utilizing, cleaning and maintaining protective
equipment provided by the company.
Material handling gloves will be provided upon hire and once a quarter there after.
Foot Protection
Safety-toe footwear that complies with ANSI-Z41.1 shall be worn in all field and shop
locations; this is a condition of employment.
Footwear shall be substantial in construction and made of solid impermeable
material in the soles and uppers that offer good protection against penetration of
liquids and sharp objects.
Additional foot protection such as rubber boots may be needed during operations
involving cleaning chemicals, caustics or solvents. The Company in these
circumstances shall provide rubber boots.
Footwear such as sandals, canvas shoes tennis shoes and other styles that do not
provide proper support or protection shall not be worn on Company Operations.
Personal Floatation Devices (Workvests / Life Jackets)
Employees who are working over or near the water except when protected by a
handrail or boarding or disembarking a vessel or working aboard a vessel (boat or
barge) shall wear a fully secured workvest or USCG approved Type I floatation
device.
Inflatable life jackets are provided by transportation companies and shall be worn
while traveling by an aircraft over water.
USCG approved Type I floatation device shall be worn while conducting platform
abandonment.
Employees visiting an offshore platform are required to wear a fully secured flotation
device when at the plus 10 level or below the lowest working level.
The immediate supervisor shall confirm with the facility operator if and when
employees may deviate from this requirement. Anytime a flotation device is no
longer an effective flotation device shall be taken out of service, reported to facility
owner or supervisor and replaced.
Employee Owned Personal Protective Equipment
Any PPE which is employee owned shall be inspected, maintained and cleaned in
occurrence with all regulatory and company requirements.
J13.6
J13.7
Page 1 of 10
Original: 7/25/05
Revised: 01/01/08
J14.1
REQUIREMENTS
Aerial lifts acquired for use on or after January 22, 1973 shall be designed and
constructed in conformance with the applicable requirements of the American
National Standards for "Vehicle Mounted Elevating and Rotating Work Platforms,"
J14.2
ANSI A92.2-1969, including appendix. Aerial lifts acquired before January 22, 1973
which do not meet the requirements of ANSI A92.2-1969, may not be used after
January 1, 1976, unless they shall have been modified so as to conform with the
applicable design and construction
Equipment shall be used in its stock configuration and only as it was intended to be
used. "Field modifications" shall only be made if written certification from the
manufacturer or a nationally recognized testing laboratory has been received.
Any articulating boom and extensible boom platforms, primarily designed as
personnel carriers, shall have both upper and lower controls for the platform.
Upper controls must be in or beside the platform within easy reach of the operator.
Lower controls must provide for overriding the upper controls. Controls shall be
plainly marked as to their function. Lower level controls shall not be operated unless
permission has been obtained from the employee in the lift, except in case of
emergency.
Follow the American National Standards Institute (ANSI) requirements when
performing electrical tests or inspecting all critical hydraulic and pneumatic
components.
Employee instructions
Employees shall be informed on the safe use of powered platforms. The guidelines
that follow were obtained from rules covering several types of powered platforms.
Employees shall:
Test lift controls each work shift before using to determine that they are in
safe working condition;
Are trained on and before operating the equipment;
Wear a full body harness and a lanyard attached to designated anchor point
in the basket; and do not "tie off" to an adjacent pole, structure, or equipment
while working from an aerial lift;
Always stand firmly on the floor of the basket, and do not sit or climb on the
edge of the basket or use planks, ladders, or other devices for a work
position;
Do not exceed boom and basket load limits specified by the manufacturer;
Move this equipment:
with people in the basket or platform, only if it is specifically designed for
this type of operation;
J14.3
only after inspecting the boom(s) to see that it is properly cradled and
outriggers are in stowed position;
only after securing the aerial device.
set brakes and outriggers, when used, on pads or a solid surface. Wheel
chocks shall be installed before using an aerial lift on an incline.
Ensure that the equipment is being operated in the safe working envelope at
all times and are not relying solely on the EMS warning system .
Not utilize the aerial lift as an elevator. Aerial lifts are to be used for their
intended purpose only. Employees shall not climb out of the aerial lift, other
than under those circumstances that have been approved by the Facility
Manager (i.e. to get into pipe racks that cannot be accessed by any other
means). In these circumstances, employees shall be properly secured with
fall protection at all times, with 100% tie-off when climbing in and out of
basket.
If the back up alarm is not operational, a spotter shall walk in front of the
aerial lift when it is being backed up.
Aerial lifts shall maintain a Safe Distance of 10 feet from all powerlines lines
Required inspections before each use
Before each use, the machine shall be visually inspected by the operator. A formal
inspection shall be done once a day and use of pre-use inspection form shall be
utilized for that inspection record. The formal inspection shall be done by a
competent person that has been identified by the facility manager.
Keep a certification record of each inspection which includes the date of the
inspection, the signature of the person who performed the inspection, and the serial
number, or other identifier, of the machine which was inspected.
The EMS system on the unit shall be tested before each use. Daily EMS function
testing shall be done daily to ensure that this system is functioning properly and all
alarms are in proper working order.
Pre-use inspections shall be documented on the appropriate inspection form (see
Attachment 1) and turned in to the Facility Manager on a daily basis.
SPIDER LIFTS (ADJUSTABLE SUSPENSION SCAFFOLDING)
Inspection
Employers should require a competent person to inspect all scaffolds and scaffold
components for visible defects before use on each workshift. Scaffolds should be
J14.4
Inspect fall
J14.5
When a secondary wire rope system is used, a horizontal lifeline secured to two or
more structural members of the scaffold may be used in lieu of vertical lifelines
Use of Structural Members as Anchor Points
Structurally sound portions of structural beams, pipes, pad-eyes, etc. must be used
to anchor lifelines for harness systems and tiebacks for suspension scaffold support
devices. Lifelines and tiebacks should be secured to separate anchor points of
structural members. Competent persons shall identify and communicate strategically
located anchor points on structural members of the platform for maintenance and
repair work. Anchor points shall have the strength to support over 5300lbs to serve
as an adequate anchor point.
GENERAL GUIDELINES
1. Post these safety guidelines in a conspicuous place and be sure that all
persons who erect, use, locate, or dismantle suspended scaffold systems are
fully aware of them and also use them in tool box safety meetings.
2. Follow all equipment manufacturers recommendations as well as all state,
local and federal codes, ordinances and regulations relating to suspended
powered scaffolding.
3. Survey the jobsite. A survey shall be made of the jobsite by a competent
person for hazards such as exposed electrical wires and obstructions that
could overload or tip the suspended powered scaffold when it is raised or
lowered. Those conditions should be corrected before installing or using or
installing powered suspended scaffold systems.
4. Inspect all equipment before use. Never use any equipment that is damaged
or defective in any way. Mark it or tag it as damaged or defective equipment
and remove it from the jobsite.
5. Erect and dismantle suspended powered scaffold equipment in accordance
with design and/or manufacturers recommendations.
6. Do not erect, dismantle, or alter suspended powered scaffold systems unless
under the supervision of a competent person.
7. Do not abuse or misuse suspended powered scaffold equipment.
overload platforms or hoists.
Never
10. Shield scaffold suspension ropes, cables, and harness system lifelines
(lifelines) from hot or corrosive processes, and protect them from sharp edges
or abrasion.
11. Inspect all scaffolds, scaffold components, and personal fall protection
equipment before each use.
12. Provide personal fall arrest system components and make sure that it is used
by all workers on adjustable suspension scaffolds.
13. Use structurally sound structures to anchor lifelines for harness systems and
tiebacks for suspension scaffold support devices. Lifelines, vertical life lines,
and tiebacks should be secured to separate anchor points on structural
members.
14. Provide proper training for all workers who use any type of adjustable
suspension scaffold or fall protection equipment.
15. Follow scaffold manufacturers' guidance regarding the assembly, rigging, and
use of scaffolds.
16. Suspension ropes and lifelines for harness systems should be shielded from
a. heat-producing processes such as welding,
b. acids or other corrosive substances, and
c. sharp edges or abrasions.
17. Such ropes should be made from material that is not adversely affected by
heat or by acids or other corrosives.
18. Suspended powered platforms must never be operated near live power lines
or sources unless precautions are taken.
19. Do not work on or install suspended powered scaffolds if your physical
condition is such that you feel dizzy or unsteady in any way, or under the
influence of alcohol or illegal drugs.
20. When welding from suspended powered scaffolds:
a. Assure platform is grounded to structure.
b. Insulate wire rope above and below the platform.
c. Insulate wire rope at suspension point and assure wire rope does not
contact structure along its entire length.
d. Prevent the bitter end from touching the ground.
J14.7
21. Inspect all rigging equipment and suspended powered platform systems daily.
22. Do not overload, modify or substitute equipment.
23. Inspect wire rope during each ascent or descent for damage.
24. Use care to prevent damage to equipment by corrosive or other damaging
substances.
25. Clean and service equipment regularly.
26. Always maintain at least four (4) wraps of wire rope on drum type hoists.
27. Do not join platforms unless the installation was designed for that purpose.
28. When rigging for another drop, assure sufficient wire rope is available before
moving the suspended scaffold system horizontally.
Proper Training of Workers
Moreno Group LLC and Subsidiaries provides workers with proper training, including
the manufacturers' recommendations for installing and operating adjustable
suspended scaffold systems and for using personal fall protection equipment.
Untrained personnel should never be permitted to work from any type of suspension
scaffold.
J14.8
Attachment 1
J14.9
J14.9.a.1
Attachment 2
J14.10
A
A1
A2
A3
A4
A5
A6
A7
YES
NO
N/A
YES
NO
N/A
REMARKS:
LIFELINES/SUPPORT LINES
B
B1
B2
B3
B4
Are there any broken strands, rust and kinks that may
weaken wire ropes? Ropes should be lubricated frequently,
especially before use in acidic temperatures or before
exposure to salt water.
Are wire rope strands cleaned and coated with oil after each
use?
Are lifelines carefully checked before and after each use? If
any lifelines are in use, they should be checked for wear,
broken or frayed cords and chemical damage
Are lines being maintained per manufacturers instructions?
REMARKS:
J14.10.a.1
PLATFORM INSPECTION
C
C1
C2
C3
C4
YES
NO
N/A
REMARKS:
J14.10.a.2
Scaffolding
Page: 1 of 10
Original: 01/01/2001
Revised: 3/12/2009
Scaffolding
Purpose
To establish the minimum guidelines for the erection, dismantling and use of
scaffolds. The intent of this guideline is to meet or exceed 29 CFR 1910.28
1910.29 and 29 CFR 1926.451.
Scope
The scope of this program is to provide guidelines to improve Moreno Group LLC
and Subsidiaries scaffolding systems.
Responsibilities
The Facility Manager / Offshore Manager or Designee is responsible for:
Overseeing this Policy to ensure that all assigned duties are being carried
out.
Being knowledgeable current with the requirements of OSHA as they pertain
to this procedure.
Reviewing all audits for compliance with this procedure.
Approval variances to apply green tags instead of yellow tags.
The Yard Foreman / Offshore Superintendent is responsible for:
Evaluating the safe use of scaffolds as an integral part of preplanning a job.
Assuring all employees reporting to them who may be required to use
scaffolds are properly trained and understand the requirements of this
procedure.
The First Line Supervisor / Offshore Superintendent (Competent Person) is
responsible for:
Evaluating and managing conditions located at jobsite.
Inspecting scaffolding to ensure it is in good condition.
Erecting scaffold per manufacturers specifications.
J15.1
J15.2
Requirements
It shall be the responsibility of all Moreno Group LLC and Subsidiaries employees to
read and comply with the following guidelines, which are designed to promote safety
in the erecting, dismantling and use of scaffolds. These guidelines are not allinclusive and do not replace other additional guidelines that may be more rigid.
Precautionary measures shall be taken when unusual conditions occur that may not
be covered by these guidelines. If these guidelines conflict with applicable federal,
other governmental statute or regulation which is more rigid, the statute or regulation
shall supersede these guidelines and it shall be the responsibility of the erector or
user to comply.
Personnel Qualifications
Scaffolds shall be erected, dismantled, moved and altered under the supervision of a
Scaffold Competent Person. The Scaffold Competent Person shall inspect and tag
all scaffolds accordingly. Employees designated as Scaffold Builders shall be
trained as per the training requirements of 1926.454(b).
Personnel who have successfully completed scaffolding training that encompasses
education of scaffolds up two bucks or less than 14 vertical height to the work
platform, may direct and/or perform the erection, modification or dismantling of
scaffolds up to this height.
Scaffold General Guidelines
All types of scaffold shall meet the following General Guidelines:
No scaffold shall be erected, moved, dismantled or altered except under the
supervision of a competent person.
Supported scaffold poles, legs, posts, frames and up-rights shall bear on base plates
and mudsills or other adequate firm foundation.
Runners shall be as close to the base as possible on all Company scaffolds.
Scaffolds shall be erected plumb and square.
Scaffolds shall be braced and rigid at all times.
The competent person should determine the feasibility and safety of providing fall
protection for employees erecting or dismantling supported scaffolds. Employers
are required to provide fall protection for employees erecting or dismantling
supported scaffolds where the installation and use of such protection is feasible and
does not create a greater hazard.
All scaffolds shall be equipped with a handrail, midrail and toeboard. Handrail height
shall be 42 inches to 45 inches.
J15.3
All scaffolds shall be equipped with proper access. Dual access/egress shall be
considered when working in operating units per National Fire Protection Association
101 Life Safety Code. Scaffold access ladders shall extend three feet beyond the
deck. Scaffolds more than thirty feet in height shall be provided with a ladder break
and rest deck with additional breaks and decks every thirty feet, thereafter. The
employer shall have a competent person determine whether it is feasible or would
pose a greater hazard to provide and have employees use a safe means of access.
)
When an overhead hazard exists, overhead protection shall be provided for persons
erecting scaffolds.
Slippery conditions on scaffold decks shall be removed or corrected as soon as
possible
When erecting scaffolds, barricade tape shall be used.
When persons are required to work or pass under scaffolds, barricades (a minimum
of six feet outside the base of the scaffold) may be used instead of the screen if
personnel do not cross the barricade. When objects center of gravity does not
extend over the toe boards, is too large, heavy or massive to be contained or
deflective by the barriers, those materials shall be secured as necessary to prevent
their falling.
Scaffolds in pipe racks that require travel between scaffolds shall have walkways of
not less than 18 inches wide, except where scaffolds must be used in areas so
narrow that platforms and walkways cannot be at least 18 inches wide, such
platforms and walkways shall be as wide as feasible and employees on those
platforms and walkways shall be protected from fall hazards by the use of guardrails
and or personal fall arresting system. Means of access/egress shall not be more
than 50 feet from the farthest point, per NFPA 101 and 1910.37.
All scaffolds should be tagged. A Red Tag shall indicate that the scaffolding is not
safe to be used. A Yellow Tag shall indicate that the scaffolding can be used with
caution and protection measures implemented (i.e.: 100% Fall Protection).
A Green Tag shall indicate that the scaffolding is safe to be used. Scaffolding may
be green tagged when these scaffolds are built at heights less than 6 feet and built
to green tag specifications. Should a scaffold not be built to green tag specifications,
then fall protection will be required with a yellow tag.
Any scaffold, no matter height, that is built next to or within its tipping radius of the
handrail to deck or platform shall be yellow tagged and require fall protection to be
worn.
Employee shall follow all instruction and color of the scaffolding tag.
Attachment 1 contains a sample scaffolding tag that can be used. Moreno Group
LLC and Subsidiaries will tag all scaffolding with Yellow Tags requiring 100% fall
protection even though the scaffolding is built to Green Tag specifications.
J15.4
There are numerous different scaffold combinations; these scaffolds shall be built to
the requirements of these guidelines and the existing OSHA Regulations for that
type of scaffold.
During the erection or dismantling of scaffolds, a fall arrest system will be utilized.
The preferred method of tie-off shall be a structural member anchor point with an
attached SRL. In those cases, where an anchor point can not be utilized, scaffold
builders shall tie off to the vertical scaffold member rosettes.
When erecting or dismantling scaffolds, workers will erect and dismantle scaffold in
10 feet stages to ensure scaffold builders have proper working surfaces (scaffold
boards) and access ladders. When erecting or dismantling scaffolds, workers shall
not work off a bare bar, unless it is impractical, approved by a competent person and
identified in the JSEA.
The throwing of scaffold material (up or down) is not permitted.
The use of leather gloves while working with scaffolds is required.
System Scaffolds
Flight bars shall be installed at intervals between six foot, six inches and seven-foot
unless otherwise specified by a registered professional engineer or customer
competent in this field.
System scaffolds that are multi-deck shall be built in accordance with 1926.451 (4)
(5) and tables L-10, L-11 and L-12, and 1910.28 (4) (5), D-13, D-14 and D-15.
Engineered systems scaffolds shall be built in accordance with engineered
drawings. Scaffolds may be erected by a plan view sketch drawn by the engineer
and may be changed during the building process only with written approval of the
engineer. Upon completion of the scaffold, the scaffold shall be inspected and the
drawing made available to the end user.
Scaffolds of unusual design or purpose shall be approved by the engineering
department and/or the safety department.
Tubular Welded Frame Scaffolds
Tubular welded frame scaffolds are available in many sizes, designed for many
different uses and shall be erected in accordance with that particular manufacturers
recommendations.
Tubular Welded Frame erected more than one-hundred twenty-five feet (125) above
the base plates shall be designed by a registered professional engineer competent
in this field.
Engineered Tubular Welded Frame Scaffolds shall be erected in accordance with
the drawing. These drawings shall be readily available for inspection.
J15.6
Tubular Welded Frame Scaffold shall meet the requirements of 1926.451 (d) and
1910.28 (d).
Manually Propelled Mobile Scaffolds
Manually Propelled Mobile Scaffolds may be erected with Tubular Welded Frames,
Tube and Coupler, Systems Scaffold or various types of manufactured mobile units.
All Manually Propelled Scaffolds are required to meet the following applicable
regulations: 1926.451 (d), Manually Propelled Scaffolds; 1910.29 (A), General
Requirements, (B) Mobile Tubular Welded Frame Scaffolds, (C) Mobile Tubular
Welded Sectional Folding Scaffolds, (D) Mobile Tube And Coupler Scaffolds And (E)
Mobile Work Platforms.
All casters on a mobile scaffold shall be equipped with a working brake, shall be
lockable and shall be locked at all times when not in motion.
Casters shall be rigidly affixed to the legs of the mobile scaffold. The use of drop
pins, pig tail pins and bolts is permissible.
Mobile scaffolds shall be square and rigid. A horizontal diagonal brace shall be
affixed to the bottom of the scaffold and every third deck thereafter in an opposing
direction. A minimum requirement of two (2) horizontal diagonal braces shall be
employed on all mobile scaffolds.
Mobile scaffolds shall have a ladder or stairway. Ladders shall be on the least
based dimension side. If a stairway is employed, the scaffold shall have a trap door
in the deck.
The decks of the mobile scaffold shall be tightly planked.
Mobile scaffolds shall be securely braced and maintained plumb.
Mobile scaffolds should only be moved on level surfaces free of holes and
obstructions or surfaces that do not exceed 3 degrees.
The force used to move mobile scaffolds shall be applied at the base.
No person shall be allowed to ride a mobile scaffold.
The height of a mobile scaffold shall be no more than four (4) times the minimum
base dimension. California requires three (3) times the minimum base dimension.
Mobile scaffolds more than forty feet (40) in height shall be designed by a registered
professional engineer competent in this field.
System Caster Adapters shall be used on all scaffold systems.
J15.7
Mobile scaffolds shall have the adjustable screwjacks affixed to the scaffold leg in
such a way as not to drop down out of the leg.
Mobile scaffold legs shall be pinned or bolted together to prevent uplift.
Poly or tarps shall not be used to enclose freestanding mobile scaffolds without
approval of the scaffold engineering department.
Cantilevers on mobile scaffolds shall not be allowed, unless designed by a
registered professional engineer competent in this field.
Erection of mobile scaffolds on the deck of a platform or barge will be performed on
a case by case basis. If an employee requests a mobile scaffolding on either a
platform or barge, Management and the SH&E Department will evaluate this
situation if a mobile scaffolding is warranted. If a mobile scaffold is erected within 6
of a handrail or edge of a barge employee shall wear fall protection, even if the work
platform of the scaffolding is below 6.
Putlogs and Trusses
Place recommended bracing between putlog/truss no more than twelve feet (12).
Aluminum Beams
Spans and widths of decks placed on aluminum beams must not exceed
manufacturers recommendations. The use of aluminum beams shall be under the
direction of the engineering department. Decorator planks (pick boards) shall not be
bridged together by planking to form a deck.
Hanging Scaffolds (Tube and Clamp Systems)
Hanging scaffolds shall meet the Requirements of scaffolding.
The area below a hanging scaffold shall be barricaded.
Training
All employees involved in erecting, dismantling, moving, operating, repairing,
maintaining, or inspecting a scaffold shall be trained by a Scaffold Competent
person to recognize any hazards associated with the work in question.
The training shall include the following:
The nature of scaffold hazards
The correct procedures for erecting, disassembling, moving, operating,
repairing, inspecting and maintaining the type of scaffold in question
The design criteria, maximum intended load-carrying capacity and intended
use of the scaffold
Moreno Group, LLC and Subsidiaries Scaffolding Procedure
J15.8
J15.9
Attachment 1
J15.10
GREEN
YELLOW
RED
J15.10.a.1
Vehicle Safety
Page: 1 of 6
Original: 01/01/2001
Revised: 04/01/2005
Vehicle Safety
Purpose
The purpose of this policy is to promote the safe usage of all Moreno Group LLC and
Subsidiaries company vehicles.
Scope
This policy addresses the responsibilities of individuals who drive company vehicles.
All drivers shall exercise Safe Driving Techniques while driving. A safe driver is one
who commits no driving errors and makes allowances for the lack of skill or improper
driving practice of the other party. The driver will adjust his/her own driving to
compensate for unusual weather, road, and traffic conditions. The safe driver
should recognize the need for preventive action in advance and should take the
necessary precaution to prevent the accident.
Responsibilities
The Facility / Site Manager / Transportation Manager or Designee is responsible
for:
Implementing the provisions of this procedure.
Ensuring that all vehicle operators have a valid operators or commercial
drivers license and insurance card located within the vehicle glove box for the
type of vehicle they will operate.
Ensure vehicle operators complete the Moreno Group LLC and Subsidiaries
Vehicle SH&E Policy Acknowledgment Form. (see Attachment 1)
Ensuring that all commercial vehicle operators meet the applicable DOT or
other regulatory requirements.
Auditing compliance with this procedure.
Periodically reviewing the driving records of vehicle operators, taking
appropriate action to address non-conformance to this procedure.
The Company Vehicle Operator is responsible for:
Complying with this procedure and operating company vehicles safely.
J16.1
J16.2
Never attempt to perform work or drive a vehicle when you are impaired by alcohol,
medication or drugs. Individuals driving Company vehicles shall not be allowed
to or transport anyone, who is carrying or possessing Drugs, Alcohol, Firearms or
etc.
Before starting out in your vehicle in the morning, clear all windows of any frost or
dew. Cleaning only a small place on a windshield does not allow for adequate
visibility. For vehicle not permanently assigned to an employee, the Daily Truck
Checklist shall be completed (see Attachment 3).
Unsafe and discourteous driving practices such as road- hogging, disregarding the
rights of pedestrians, violating traffic regulations, and deliberate recklessness of any
kind are prohibited.
Drivers of automotive equipment operating on company property must adhere to all
applicable traffic regulations.
Getting in and out of a vehicle while it is in motion is prohibited, as is riding
anywhere on the vehicle not designed for passengers. Do not get out of a vehicle
and leave the motor running, or drive a vehicle with a door open.
Allowing individuals to ride in the bed of a truck will only be allowed within Moreno
Group LLC and Subsidiaries facilities and not on any roads and/or highways outside
our facility gates. Individuals riding within a bed of a truck must remain seated at all
times not leaning against the tailgate of the truck or may there be any loose material
in the bed of the truck while employees are riding in the bed of the truck.
Driving at the posted speed limit can be too fast for safety in some situations. The
driver should use good judgment and proceed at a pace suitable to the conditions of
the vehicle, the road, the traffic and the weather.
Never add gasoline or diesel fuel to the fuel tank of a motor vehicle while the engine
is running.
Smoking is prohibited near a vehicle being refueled.
All hazardous materials must be carried in approved containers, appropriately
labeled and they must contain shipping papers. Flammable liquids or combustible
liquids are not to be carried in trunks of vehicles or within the passenger area of the
vehicle.
Except in emergencies, gasoline must not be carried inside passenger cars or the
cabs of trucks. When an emergency requires that it be carried in these places, it
should be in an Underwriters Laboratories (UL) approved container that is sealed
tight to prevent the leakage of gasoline or gasoline vapors.
It is recommended that cellular phones are not being utilized by the driver while
vehicle is in motion, unless hands free unit has been installed in vehicle.
J16.3
Attachment 1
J16.4
2.
3.
4.
5.
I will check the vehicle for proper operations and not drive the vehicle if
there is a reason to believe the vehicle is not safe to drive.
6.
I will comply with all regulations applicable to the area in which I will be
operating the vehicle.
7.
8.
9.
J16.4.a.1
Attachment 2
J16.5
Damage to Other
Vehicle
Damage to
Vehicle
Time &
Place of
Accident
Company
Vehicle
Work
Time:
Location of Accident
Company Vehicle
Identification Number (VIN):
Description of Damage:
Name of Owner:
Address:
Name of Driver:
Address:
Telephone Number:
Description of Damage:
Make of Vehicle:
Name:
Witnesses
SSN:
Was Employee Injured?
Yes
No
Model:
Year:
Address:
Telephone Number:
Name:
Address:
Occupants of
Vehicles
Telephone Number:
Name:
Address:
Telephone Number:
Name:
Address:
Telephone Number:
J16.5.a.1
Yes
No
Employees Name:
Employees
Signature:
J15.5.a.2
Date:
Attachment 3
J16.6
DATE:
TRACTOR/
TRUCK NO.
Air Compressor
Air Lines
Battery
Body
Brake Accessories
Brakes, Parking
Brakes, Service
Clutch
Coupling Devices
Defroster/Heater
Drive Line
Engine
Exhaust
Fifth Wheel
Frame and Assembly
Front Axle
Fuel Tanks
TRAILER(S) NO.(S)
Brake Connections
Brakes
Coupling Devices
Coupling (King) Pin
Doors
TIME:
ODOMETER READING
Horn
Lights
Head - Stop
Tall - Dash
Turn Indicators
Mirrors
Muffler
Oil Pressure
Radiator
Rear End
Reflectors
Safety Equipment
Fire Extinguisher
Reflective Triangles
Flags - Flares - Fuses
Spare Bulbs & Fuses
Spare Seal Beam
Hitch
Landing Gear
Lights - All
Roof
Suspension System
A.M. P.M
Suspension System
Starter
Steering
Techograph
Tires
Tire Chains
Transmission
Wheels and Rims
Windows
Windshield Wipers
Other
Tarpaulin
Tires
Wheels and Rims
Other
REMARKS: ________________________________________________________
DATE:
DRIVER'S SIGNATURE:
DATE:
J16.6.a.1
J16.6.a.2
LIGHTS
HORN
MIRRORS
BRAKES
______
______
______
______
______
______
Waterfront Safety
Procedure
Page: 1 of 5
Original: 09/01/2007
Revised:
J17.1
If scope of work changes, Stop All Work and relate information to all affected
personnel by means of safety meeting and JSEA.
Continually communicate employees responsibility to use their Stop Work
Authority for unsafe and environmentally unfriendly conditions.
The Safety, Health and Environmental Department or Designee is
responsible for:
Training or coordinating the training of managers, supervisors and hourly
employees on the Waterfront Safety Procedure.
Issuing of Hot work Permits for all barges.
Periodically auditing the quality of checklists, JSEAs and safety meeting
forms to ensure they reflect safe practices.
Periodic auditing of waterfront work activities to ensure that all applicable
precautions indicated on the JSEA are being implemented and that all safe
work practices are being followed.
Participating in pre-job safety meetings and JSEAs on a periodic basis to
ensure compliance.
The Employee is responsible for:
Actively participating in the development and review of the Waterfront Safety
Program.
Performing pre-job check of all equipment and PPE to ensure that they are in
a safe condition.
Ensuring that all safe work practices are being implemented while performing
waterfront work tasks and report all incidents associated with waterfront work
operations. Employees are also responsible for using Stop Work Authority
anytime a condition arises that is potentially unsafe.
Completing assigned activities in a safe manner.
Advising their supervisor when the conditions or situations of the current task
changes.
J17.2
Requirements
The Waterfront Safety Procedure is to implement Safe Work Practices and
controls when working around waterfront locations with employees, material and
equipment.
The Facility Manager is responsible for the implementation & enforcement of this
procedure, as well as other procedures that pertain to the scope of work being
performed. The SH&E Department shall assist in routine auditing of the
procedure and implementation of the procedure to ensure that the procedure is
being complied with.
Hazards
The following hazards are found while working around waterfront locations.
1. Falling into waterway from bulkhead locations.
2. Falling off of walkways onto barges that are in slips.
3. Walkways falling off of barges that are not properly secured.
4. Machinery working on barges that have the potential of falling into
waterways.
Methods of Compliance
Methods of compliance that reduce or eliminate the risk of exposure include
Engineering Controls, Administrative Controls, Medical Surveillance, Safe Work
Practices, and Training in the use of Personal Protective Equipment (PPE) and
any associated equipment.
Engineering Controls
Engineering Controls, methods of isolating or removing a hazard from the
workplace, are one of the most effective methods of hazard reduction.
Engineering controls should be employed first and, if the hazard remains,
personal protective equipment will also be used.
Designated walkways shall be placed on each loadout or load-in barge.
This shall be done by the use of scaffold poles or use of 3/8 wire rope so
that all employees working on the structures on the deck of the barge will
not have to don PFTs.
Temporary handrails shall be posted along the sides of the barge, if
possible and/or feasible, so that employees working on the deck of the
J17.3
barge will not have to don PFTs. This shall be accomplished by the use
of scaffold poles and/or 3/8 wire rope.
Walkways on all structures in the waterways shall be secured to structure
with the use of two padeyes and shackled to the padeye with the use of
wire rope.
Tarping off of structures being blasted on over or near waterways shall be
accomplished by the following:
o All structures being blasted on while over waterways shall be tarpped
off with scaffold poles and wrapped with blasting tarps. This shall be
done to minimize the amount of material being emitted from blasting
operations.
o Structures shall not be placed within 6 of bulkhead areas to minimize
any emissions into waterway from blasting operations. Any material
that is near any bulkheaded area shall be enclosed with blasting
screens to minimize emissions to the waterways.
Administrative Controls
Auditing of work sites to ensure a safe work area.
Signs shall be posted along bulkheaded areas identifying that no
unauthorized employee is allowed within 6 of bulkheads.
Signs shall be posted 90 apart and will be posted on poles along
bulkhead.
Signs shall be 36 x 24 in size.
Machinery working on barges shall be accompanied by a spotter. Anytime
any machinery shall be moved on barges, a designated spotter shall be in
place to flag the equipment to prevent machinery from being driven off of
barges.
Each barge will be evaluated and receive a Gas Free Certificate from a
Marine Chemist prior to any hot work being performed on the barge. Each
day after the evaluation and issuing of the Gas Free Certificate by the
Marine Chemist, a gas detection evaluation and hot work permit shall be
issued by the SH&E Department or designee prior any hot work being
performed on the barge.
J17.4
J17.5
Page: 1 of 13
Original: 01/01/2001
Revised: 05/01/2008
J18.2
Fire extinguishers shall be maintained in a state of readiness for instant use. The
type of extinguisher required is determined by the type of fire hazards nearby.
Whenever there are cracks or holes in the floor, nearby windows, open doorways,
etc., precautions shall be taken such that no readily flammable or combustible
materials on the other side shall be exposed to sparks.
Fire watch shall be required whenever welding or cutting is performed in location not
designated as safe welding and burning area.
Fire watch shall have fire
extinguishing equipment readily available and be trained in their use. They shall be
familiar with procedures for initiating the emergency evacuation procedure in the
event of a fire. They shall only attempt to extinguish a fire when the fire is obviously
within the capacity of the equipment available. A fire watch shall be maintained for
half an hour after the completion of welding or cutting operations to detect and
extinguish smoldering fires.
No hot work shall take place without authorization by the Moreno Group LLC and
Subsidiaries Supervisor/Superintendent or designated client personnel responsible
for such operations. This person shall designate specific precautions to be taken in
the form of a written hot work permit.
Any Moreno Group LLC and Subsidiaries Supervisor or designee who is expected to
issue hot work permits shall be trained in permit issuing and gas detection
monitoring.
Hot work permits shall be issued by the supervisor or trained designee. The permit
shall only be issued till the end of the shift. Operation shall be stopped if any
conditions or situations occur which is not addressed on the permit.
The Moreno Group LLC and Subsidiaries Offshore Superintendent shall ensure all
MMS requirements are met prior to accepting a Hot Work Permit from a client
representative. These requirements are as follow:
Slag, sparks or other burning materials shall be prevented from contacting
equipment which contains flammable in an area within 35 feet of the work or
any level below where sparks may reach. Metal shields, flame resistant
guards or curtain may be used to prevent contact if the equipment cannot be
relocated from the work area.
If hot work is within 10 feet of the well bay, all wells must be shut in at the
Surface Safety Valve.
If hot work is within 10 feet of production equipment, tanks or flanged piping,
production shall be shut in at the Surface Safety Valve.
If drilling, well completions, workovers, well servicing or wireline operations
are in progress, no hot work will be allowed unless the well contains kill
weight fluid or the well is plugged and formation hydrocarbon entering the well
bore precluded.
J18.3
Personnel performing fire watch will remain on duty for a period of 30 minutes
after hot work operations have been completed.
Hot work shall not take place in unauthorized areas, in sprinkled buildings while such
protection is impaired, in the presence of explosive atmospheres or in areas where
such an atmosphere may develop, or near large quantities of exposed, readily
ignitable material.
Facility / Site Management shall recognize its responsibility for the safe usage of
welding and cutting equipment by designating an individual responsible for
authorizing cutting and welding operations and by ensuring that cutters and welders
and their supervisors are suitably trained in the safe operation of their equipment.
Also, management must advise all contractors about flammable materials or
hazardous conditions onsite of which they may not be aware.
Welding or cutting shall not be performed on used containers such as drums, barrels
or tanks until such containers have been thoroughly cleaned to ensure that no
materials remain that might ignite or produce toxic vapors. Any pipe lines or
connections to the drum or vessel shall be disconnected or blanked. All hollow
spaces, cavities, or containers shall be vented to permit the escape of air or gases
before preheating, cutting, or welding. Purging with inert gas is recommended.
Adequate ventilation shall be provided at all times. A number of potentially
hazardous materials are employed in fluxes, coatings, coverings, and filler materials
used in welding or cutting. These include, but are not limited to, the following:
Cadmium
Fluorides
Hexavalent Chromium
Zinc
Lead
Beryllium
Mercury
In all cases where these or other hazardous materials are present, special
precautions must be taken. Ventilation usually must be increased, and in no case
should these fumes be inhaled. Oxygen must NEVER be used for ventilation.
Potential hazards from burning and welding activities must be evaluated and proper
safeguards taken. Potential hazards include:
Electric shock, burns, radiant energy, fires and explosions. All precautions
shall be taken to guard against these hazards.
J18.4
Hearing protection
Following safeguards on MSDS and product labels
Using equipment per manufacturers recommendations
Clothing worn by personnel involved in burning and welding activities should:
Be made of cotton or wool rather than a synthetic fabric
Have long sleeves and button collars
Have no open front pockets or turn-up cuffs
Protective clothing required for welding, cutting and brazing activities may include:
Leather or other suitable gloves (may be insulated)
Aprons of leather or other suitable material
Leggings or high boots (for heavy work)
Safety shoes
Hard hats
Hearing protection
Eye protection is required for both welders and helpers involved in welding and
cutting activities. ANSI approved safety glasses with side shields must be worn in
addition to the welders helmet with the appropriate shaded lenses or face shield.
Mechanical ventilation must be used when natural ventilation is unacceptable or the
concentration of contaminants is too high for welders and co-workers. Types of
mechanical ventilation include:
Local exhaust (preferred method)
Local forced air (such as a fan)
General area (such as roof exhaust fans)
The manufacturers instructions are to be followed for all equipment used in burning
and welding activities.
Fire Protection required for hot work activities must be evaluated for each job and
precautions specified on the Permit. The following precautions may be required:
J18.6
Gas cylinders must only be used for the purpose intended by the supplier.
Cylinder valves must be closed when the work is finished, the gas released
from the regulator, the regulator removed, and the protective cap installed.
Leaking gas cylinders should:
Be taken out of use immediately
Have the valve closed
Properly tagged & supervision notified.
Warning signs posted as necessary.
The supplier notified and their instructions followed.
Regulators used with compressed gas cylinders must meet with the following
requirements.
Only regulators approved by recognized testing agencies such Underwriters
Laboratories, Inc. or Factory Mutual should be used at Moreno Group LLC
and Subsidiaries Facilities / Sites.
Regulators should have both high and low pressure gauges.
Oxygen regulators should have a safety relief valve and safety vent covers on
the high pressure gauge.
Regulator treads should conform to industrial standards. (ANSI / CGA V-11987).
Regulators should be clearly marked as to their type of service.
Regulators must always be handled carefully and repaired only by the
manufacturer.
Leaky and damaged regulators or regulators showing creeping pressure
changes must be taken out of service and repaired.
The pressure-adjusting device should be released whenever regulators are
connected but not in use.
Cylinder valves should never be opened until the regulator is drained of gas
and the pressure-adjusting device is fully released.
All regulators shall contain a check valve and a flash back arrestor.
J18.9
Hoses and hose connections used with compressed gas cylinders must meet the
following requirements.
Hoses and connections must be properly identified. Color codes for hoses
should be:
Red - fuel-gas hose.
Green - oxygen hose.
Black - inert gas or air hose.
Connection marking are usually as follows:
Std-Oxy for oxygen.
Std-Acet for acetylene.
The following safety rules apply to the use of hoses in welding and cutting
activities.
Backflow protection shall be provided by an approved device that will
prevent oxygen from flowing into the fuel-gas system or fuel from flowing
into the oxygen system. (Follow vendor installation instructions)
Flash-back protection shall be provided by an approved device that will
prevent flame from passing into the fuel-gas system. (Follow vendor
installation instructions)
Do not use hoses that are longer than necessary.
Prevent kinking of hoses.
Prevent hose damage from vehicular or pedestrian traffic.
Repair or replace damaged or leaking hoses at once. (Do not repair with
tape.)
Inspect hoses frequently. Test for leaks with normal pressure using a
soapy water solution.
Protect hoses from sparks, slag, grease, oil, chemicals, etc.
Torches used for welding and cutting must meet the following requirements.
Only torches approved by recognized testing agencies such as Underwriter
Laboratories, Inc. or the Factory Mutual should be used.
The following safety precautions are to be followed when using torches:
J18.10
The
Before changing torches, the gas must be shut off at the regulator. -- NOT
by crimping the hose.
Torches should be lit in a manner which does not endanger personnel,
equipment or nearby objects.
A torch should not be put down until it is completely shut off.
Torches should NOT be hung on regulators or cylinders.
Torches must be operated per the manufacturers recommendations.
When welding or cutting is to be stopped for some period of time (such as
lunch break or over night) the following is required.
All torches shall contain a check valve and a flash back arrestor.
Oxygen and acetylene cylinder valves must be closed.
Torch valves must be opened and all gas pressure relieved from the hoses
and regulator.
Then close the torch valves and release regulator pressure screws.
Arc welding and cutting must meet the following requirements.
The personnel using this equipment must be knowledgeable of the
manufacturers operating instructions and the equipment must be operated in
accordance with the manufacturers recommendations.
Welding cables must be inspected frequently and maintained in good
conditions. Defective or damaged cables should be replaced immediately.
All electrical connections should be securely fastened.
Welding cables should be kept orderly to minimize tripping hazards and
should not lie in water, oil or spilled materials.
When arc welding is performed in wet or damp conditions, special
precautions must be taken to protect the welder from electric shock.
Safety shields or barricades shall be placed around welding jobs where
needed to protect others from direct rays of electric arc. These direct rays
may cause flash burns and / or eye damage.
J18.11
J18.12
Attachment 1
J18.13
Ending time of
work
Yes
N/A
Yes or No
Safety Glasses
Gloves
Protective Clothing
Other:
Initial gas concentrations must be zero percent LEL before any hot work can begin.
The fire watch shall conduct continuous monitoring with a portable gas detector.
Permit issuer shall document the initial readings below:
LEL %
Oxygen
All Precautions Listed On This Permit Are Understood, Implemented And Will Be
Maintained Until The Hot Work Is Complete
Person Performing
Hot work
Fire Watch
Designated Person
in charge
Permit Issued By
Company
Company
Company
Company
J18.13.a.1
Page: 1 of 5
Original: 01/01/2001
Revised: 01/01/2008
K1.1
K1.2
K1.3
Monthly with the assistance from the Safety, Health and Environmental Department,
Management will conduct and document a SH&E Management and Supervisor
meeting.
Onshore employees will be recertifying their Annual Fitness to Work Certification by
utilizing; initialing and signing the Onshore SH&E Meeting Form (see Attachment 1).
Tailgate Safety Meetings
Daily Tailgate Safety, Health & Environmental Meetings are to allow all employees
to discuss the Daily Operation and to evaluate their work environment for safety
hazards.
To prepare employees for the daily operation, the First Line Supervisor or
Superintendent prior to beginning work shall conduct a Daily Tailgate Safety
Meeting (see Attachment 1).
The Tailgate Safety Meeting allows employee(s) and / or supervisor(s) to discuss
the task at hand, hazard(s) associated with the task, elimination of the hazard(s) or
minimizing the exposure to the hazard(s) (i.e. Job Safety & Environmental Analysis).
The tailgate meeting which are conducted offshore or off-site shall be documented
on the SH&E Meeting Form.
K1.4
Attachment 1
K1.5
Meeting Content:
N No
Yes
Yes
Name of Attendees
Signature of
Attendees
Initial
Name of
Attendees
Signature of
Attendees
N No
N No
Initial
K1.5.a.1
Meeting Content:
N No
Yes
Has anything changed from your initial (annual) Fitness to Work Certification?
Yes
N No
N No
Initial next to signature if your Fitness to Work Certification has not changed, if it has see your
supervisor to complete a new Fitness to Work Certification.
Was a Job Safety & Environmental Analysis reviewed or developed?
Name of
Attendees
Signature of
Attendees
Initial
Name of
Attendees
Yes
Signature of
Attendees
N No
Initial
K1.5.a.2
Page 1 of 5
Original: 7/11/2002
Revised: 05/01/2009
L1.1
L1.2
Attachment 1
L1.3
1st
2nd
3rd
Quarters
4th
1st
2nd
3rd
Quarters
4th
1st
2nd
3rd
Quarters
4th
1st
2nd
3rd
Quarters
4th
1st
2nd
3rd
4th
Number of SH&E
Meetings
Number of
JSEAs
Number of
BSP Observations
Number of Team
BSP Observations
Number of Weekly
Audits
Number of Monthly
Audits
Number of Near
Miss Incidents
Number of SH&E
Incidents
Number of
Environmental
Incidents
Number of Work
Group Investigations
L1.3.a.1
Attachment 2
L1.4
Moreno Group LLC and Subsidiaries Monthly SH&E Performance Targets Scorecard
Week 1
Actual Targets
Week 2
Actual Targets
Week 3
Actual Targets
Week 4
Actual Targets
Totals
Actual Targets
Attachment 3
L1.5
___________________________________
___________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
WAY(S) TO ADDRESS AREAS IN NEED OF IMPROVEMENT ON JSEA'S:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
WAY(S) TO ADDRESS AREAS IN NEED OF IMPROVEMENT IN SH&E MEETINGS:
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
SUPERVISOR / SUPERINTENDENT SIGNATURE
REVIEWING MANAGER'S SIGNATURE
L1.5.a.1
New Employee
Orientation/Safety, Health
& Environmental Training
Page: 1 of 5
Original: 01/01/2001
Revised: 11/01/2008
M1.1
M1.3
Attachment 1
M1.4
Moreno Group LLC and Subsidiaries New Employee Orientation / Safety, Health and
Environmental Training Requirements
New Employee Orientation / SH&E Training Requirements:
History and Goals
Moreno Group LLC and Subsidiaries Orientation (Handbook)
Reporting incidents, Alcohol and Drug Policies, Firearms Policies, Back Injury Prevention
and Stop Work Authority
Hearing Conservation
Accident Prevention Signs, Tags and Labels
Fire Prevention / Portable Fire Extinguisher
Welding, Cutting and Brazing / Fire Watch
Control of Hazardous Energy (Lockout/Tagout)
Fall Protection
Access to Medical Records
Personal Protective Equipment
API RP 2d Rigging
Electrical Safety for Non Electrical Workers
Additional Training for Painters and Blasters
Confined Space Entry (Awareness)
Hazard Communication
Respiratory Protection (i.e. Painters & Blasters)
HAZWOPER / DOT HM 126f (Awareness Level)
RCRA
Scaffolding (End User)
Waste Minimization
Evacuation Plan
Abrasive Blasting
Bloodborne Pathogens
Hand Injury Prevention
Job Safety and Environmental Analysis (JSEA)
Behavior Based Safety
Additional Training for Supervisors
Offshore Orientation
Marine Debris Awareness
First Aid / CPR
Management of Change (MOC) Awareness
Bloodborne Pathogens
Spider Work Basket
Fall Protection Competent Person / Rescue
Hilti Gun
Scaffolding Competent Person
Facility Security
Moreno Group LLC and Subsidiaries Safe Work
Incident and Injury Free Orientation
Practices
SH&E Job-site Specific Training Requirements:
Confined Space Entry and Attendant
Offshore Crane per API 2d
Electrical Safety for Electrical Workers (i.e. Electricians)
Forklift
RCRA (Painters / Blasters)
HUET / Water Survival
DOT HM 126 F (i.e. Truck Drivers)
Mobile Equipment (i.e. Aerial Lift, Cherry Picker, Crawler Crane, etc.)
Defensive Driving (i.e. Truck Drivers and Salesmen)
Fall Protection Competent Person (Superintendents)
Fall Protection Rescue System (Superintendents)
First Aid / CPR and Bloodborne Pathogens (i.e. Supervisors and Superintendents)
Spill Prevention, Control and Countermeasures (covered facilities)
Stormwater Prevention Plan (covered facilities)
T-2 Production Safety Systems (i.e. I & E Offshore Division)
M1.4
Attachment 2
M1.4
M1.5.a.1
Page: 1 of 6
Original: 01/01/2001
Revised: 01/01/2006
person providing the training is the mentor, and the learner is the Short Service
Employee (SSE). Mentoring is recognized as a valuable component of the learning
and training process.
Moreno Group LLC and Subsidiaries Facility Manager or Project Manager The
Moreno Group LLC and Subsidiaries employee who originated the project/job
process (i.e. Offshore Manager, Yard Foreman, etc).
Moreno Group LLC and Subsidiaries First Line Supervisor or Superintendent
Individual responsible for the onsite supervision of employees. This individual shall
demonstrate leadership abilities, knowledge and skills within designated operations
to lead and teach personnel.
Short Service Employee (SSE) Moreno Group LLC and Subsidiaries and / or
Contractor Employee with less than (6) six months in the same type of job, or
employment with their employer.
Short Service Employee Mentor Each Short Service Employee (SSE) shall be
assigned a Mentor. This Mentor shall be an employee with at least one (1) year
experience working experience with employer.
Requirements
Notification
The Moreno Group LLC and Subsidiaries Facility Manager or Project Manager or
Contractor Management will ensure that the affected Offshore Superintendent is
notified of any SSE on their project/job. This notification shall be through the
submitting of the Moreno Group LLC and Subsidiaries Short Service Employee
Notification form (see Attachment 1) for all offshore employees and contract
employees.
The Moreno Group LLC and Subsidiaries First Line Supervisor, Offshore
Superintendent or Contractor Management must assign an appropriate mentor to
the SSE before this SSE arrives to a work-site.
The Moreno Group LLC and Subsidiaries Offshore Superintendent or Contractor
Management must document the Mentor assignment on the Moreno Group LLC
and Subsidiaries Short Service Employee Notification form.
Short Service Employee Orientation Requirements
Contract Personnel
Each Short Service Employee shall be provided a Safety, Health and Environmental
(SH&E) orientation upon arrival to Moreno Group LLC and Subsidiaries facilities.
Moreno Group LLC and Subsidiaries Personnel
M2.3
Prior to assignment to their designated position, the new employee will receive a
General SH&E Orientation by the Hiring First Line Supervisor or Manager. This is
documented on the Conditional Job Offer form. Upon completion of this orientation
the employee will receive an Employee Benefit Orientation from the Human
Resource Department. At this point, the employee will be scheduled for next
scheduled New Employee Orientation / SH&E Training for their position. All new
employees hired for offshore will be unavailable for their work assignment until they
have completed their required training.
Those employees whose work assignment is in the office shall receive an Office
Orientation from their Manager or their Project Manager.
Short Service Employee Training Requirements
Moreno Group LLC and Subsidiaries Facility Manager or Project Manager shall be
ensure that each Short Service Employee (SSE) is properly trained in:
The hazards present in the work place.
The procedures, processes and personal protective equipment developed to
prevent these hazards from causing injuries, properly damage and / or
environmental incidents, and
The skills necessary to conduct their assigned jobs safely and efficiently while
providing product quality and economy.
The Facility Manager or Project Manager or particular Contractor Management shall
ensure that each Short Service Employee (SSE) is properly trained as per Federal,
State
and
Industry
requirements
before
starting
work,
when:
The employee is first hired
The employee is appointed a new job assignment, and
The employee is exposed to new substances, processes, procedures,
equipment, etc. that represent a new hazard to the employee.
Moreno Group LLC and Subsidiaries Facility Manager shall refer to Moreno
Group LLC and Subsidiaries New Employee Orientation / SH&E Training
Program and the Contractor Management shall refer to the Moreno Group
LLC and Subsidiaries Contractor SH&E Program for minimum facility
requirements.
Short Service Employee Supervision
A SSE. sticker must identify each Short Service Employee. This sticker shall
be placed on both the left and right sides of the SSEs Hard Hat. Moreno
Group LLC and Subsidiaries Contractors may use their own method of
identifying their SSE. Contractor First Line Supervisor will be responsible for
M2.4
M2.5
Attachment 1
M2.6
I. SSE Information
Contractor Company
Name:
Request
Date:
SSE Name:
Date of
Employment:
Current Job Title
Years Oil Field
Experience in Current
Exp
Pos
Is this employee in compliance with your Substance Abuse
Policy?
Yrs
Have site contractor and SH&E policies been reviewed with SSE?
Who has been assigned as the SSEs
mentor?
Mentors Experience:
List all training provided to the SSE:
SSE(s) identified
by:
Yrs
Ye
s
Ye
s
Mo
s
N
o
N
o
Mos
Date
M2.6.a.1
Page 1 of 9
Original: 07/11/2002
Revised: 05/1/2009
M3.1
The eight undesirable events and how they effect safe production:
Over pressure
Underpressure
Liquid overflow
Gas blow-by
Leak
Excess temperature in a fired component
Direct ignition
Excess combustibles in a firing chamber
What a process safety system is and how its works.
Definitions and terminology of terms used in the offshore environment.
What an emergency support system is and what it does.
What type devices are used to protect us from these undesirable events.
Level Safety High/Low
Pressure Safety Hi/Low
Pressure Safety Valve
Flow Safety High/Low
Shut down and Blow down valves
Surface Safety Valves
Flow Safety Valve
Temperature Safety High/Low
Burner Safety High/Low
Subsurface Safety Valves
Gas Detection equipment
M3.4
Other Support systems covering containment, fire loop, other fire detection
and prevention equipment, and facility machinery, such as offshore cranes,
compressors, pumps, generators, chemical injection, and flaring equipment.
How to use the API-14C in determining what safety devices that will be needed to
protect us from these events and where they need to be located. The testing
requirements and tolerances. The categorizing of all process components. Primary
and Secondary protection. Limitations, malfunction, and failures of safety devices.
How to fill out a Safety Analysis Function Evaluation chart and what its use is.
How to used the Safety Analysis Checklist.
How to identify safety devices and components and what symbols are used to
indicate these on required drawings.
What the Emergency Support System is and what it does.
30 CFR Rules and regulations concerning the safe production of oil and gas in
O.C.S. waters. Pollution prevention, waste requirements, and reporting
requirements.
Hands on & classroom lessons on actual safety devices.
How to read flow diagrams and pneumatic schematics.
Proper record keeping and procedures as associated with their forms.
Government inspection criteria and associated pinc list for references on
guidelines of inspections.
Teaching and Presentations Methods:
Method used during the course will include a presentation layout that follows the
format of the training manual.
Methods used include a computer presentation projected on a television set, where
the trainee follows along in the manual. Presentation will be supported by verbal
lecture. Class participation is encouraged and trainees are encouraged to asked
questions during all phases of the course.
During the course progression, slide projection will also be used as additional
support to the subject matter. Discussion of the slide projection will also be
encouraged. Additional handout material is used on some of the presentation
process, along with and slide projection to support the areas being discussed.
The course incorporates 4 (four) learning aides. Lecture (verbal), PowerPoint
(visual), slide projection (visual, verbal, and written) and Handouts (written, which
includes practice worksheets).
M3.5
During discussion of pressure safety device set points and tolerance, which requires
some math skills, worksheets are handed out for additional exercise purposes.
Hands on training is done is small groups. Usually an experienced trainee is group
with a less experienced trainee.
Any tricks of the trade, or lessons well learned, is encouraged and passed on to
the less experienced trainee. Class discussion of these lessons shows human
error, malfunctions, failures or other possible causes of safety device problems.
Training guidelines now follows option 2 of the new Subpart O as per 30 CFR
Subpart 250.1500.
Employee Competency Verification
All authorized employees will be given the Pre-Test, which will be a timed
examination of multiple choice, true / false and hands-on questions and/or cases
which will be of sufficient length to confirm the employees competency.
All authorized employees will take the basic training final competency examination
which will be a timed examination of multiple choice, true / false and hands-on
questions and/or cases which will be of sufficient length to confirm the employees
competency and understanding of the topics covered. The examination will be
designed so the probability of like examinations will be reduced. A test score of
80% or greater will be required for successful completion. Each Moreno Group LLC
and Subsidiaries employee must have successfully completed examinations or
practicals for those duty levels for which he/she is responsible, before assuming
the authorized employee duties. If the authorized employee misses any portion of
the session, the missed instruction time must be completed prior to the beginning of
the final examination.
Employees will be required to solve practical operational case studies including
performing prescribed hands-on operations, either as a pre-test or upon
completion of a formal training session. In some cases, the authorized employee
may be asked to demonstrate the correct operation(s) and/or practicals, without
actually performing the operation(s), to assure workplace safety.
Internal Audit of Authorized Employees Production Safety Systems Training
Moreno Group LLC and Subsidiaries will use internal auditing or third party auditors
to audit our Production Safety System Training Program annually. These audits
may include the following:
Audit of training program and plan for applicability with current operations and
regulatory requirements.
Audit of instructor credentials
M3.6
M3.7
Telefax 337-365-8135
M3.8
Attachment 1
M3.9
2.
3.
High Level
High Pressure
High Temperature
High Fuel
What is the detectable Abnormal Condition for Direct Ignition Source (hot
surfaces)?
a.
b.
c.
d.
5.
4.
causes an ESD
is detectable
occurs in a process component when an operating variable ranges
outside of its normal operating range
may be a flow safety
High Temperature
Low Temperature
High Level
Low Pressure
Low Level
High Pressure
Low Temperature
Low Pressure
M3.9.a.1
6.
7.
8.
Liquid overflow
Low liquid
Gas discharge
Gas blowby
The Primary and Secondary protection for Under Pressure (pressure vessel)
is
a.
b.
c.
d.
M3.9.a.2
11.
What is the Primary and Secondary protection for Liquid Overflow (pressure
vessel)?
a.
b.
c.
d.
10.
9.
High Level
Over Pressure
High Temperature
Low Pressure
12.
13.
The Primary and Secondary protection for excess temperature (stack) are
a.
b.
c.
d.
14.
When testing with a hand pump, why is it important to reduce pressure using
the bleed off needle valve instead of using the pump vent valve?
a.
b.
c.
d.
18.
under pressure
process shutdown
malfunction
platform safety system
Which of the following contains an item that is NOT one of the eight
undesirable events?
a.
b.
c.
d.
17.
shutdown
failure
fire loop
back flow
16.
15.
a.
b.
c.
d.
19.
Piping that directs the well stream from the process well head to the first
downstream process component is known as
a.
b.
c.
d.
20.
d.
M3.9.a.4
The high pressure shut in sensor located on a pressure vessel should be set
a.
b.
c.
d.
23.
Flowlines are equipped with high and low-pressure sensors. But in all cases,
the high pressure shut in sensor shall be set
a.
b.
c.
22.
Vent System
Flowline
Sensing Line
Header System
21.
Bottle emptied
Capped and secured upright to a dolly
Remove cap and attach test manifold
Bleed down to manifold
24.
25.
26.
0 1,000 psi
0 5,000 psi
0 3,000 psi
0 1,500 psi
The Surface Controlled Subsurface Safety Valve (SCSSV) shall close in not
more than ______________ after the closure of the closure of Surface Safety
Valve (SSV).
a.
b.
c.
d.
29.
When testing a system with a PSH of 1150 and a PSL of 850, you should use
a gauge with a range of
a.
b.
c.
d.
28.
If a quick connector will not plug into the test panel, you should
a.
b.
c.
d.
27.
The difference between pressure at the beginning and end of the test
manifold
The difference between a sensors actuation point and its reset point.
The difference between PSH and PSL readings
A punk rock group
45 seconds
1 minute 45 seconds
2 minutes
None of the above
M3.9.a.5
30.
31.
Fuel or power for firewater pump drivers shall be available for at least _____
minutes of run time during platform shut in.
a.
b.
c.
d.
32.
Quarterly
Weekly
Monthly
Daily
M3.9.a.6
Annually
6 months
Monthly
None of the above
35.
Every 3 months
Monthly
Annually
Every 6 months
34.
15
25
30
60
33.
Daily
Weekly
Bimonthly
Monthly
36.
37.
38.
30 days
Semi annually
Every 3 months
Monthly
annually
Semi annually
Quarterly
Monthly
Annually
Daily
Weekly
Monthly
Annually
Daily
Weekly
Monthly
40. The lessee for each surface and subsurface device shall maintain records for
a period of
a.
b.
c.
d.
5 years
2 years
1 year
7 years
41. Offshore platforms in federal waters of the Gulf of Mexico are regulated by
the U.S. Department of the Interior through the
a.
b.
c.
d.
M3.9.a.7
Sea State
Meteorological conditions
Lunar Phase
Both a and b
The taxpayer
The Federal Government
The lessee
The nearest state
44. Which item below lists all process components and Emergency Support
System, with their required safety devices, and should list the functions to be
performed by each device?
a.
b.
c.
d.
45. An automatic well head valve assembly that will close upon loss of pressure
supply is known as a/an
a.
b.
c.
d.
Blowdown valve
Manual Master valve
Manual Wing valve
Surface Safety valve
M3.9.a.8
ESD
ESS
ESP
NPDES
47. A fired vessel with the burner fuel controlled by an automatic temperature or
pressure controller is considered to be a/an
a.
b.
c.
d.
48. What type of materials are fusible elements normally made of?
a.
b.
c.
d.
Stainless steel
Metallic plugs that can melt
Paper
Carbon steel
49. The preferred UV detector system, which used two heads across from each
other to confirm a fire, is known as
a.
b.
c.
d.
Double cross
Cross-zoning
Cross-firing
None of the above
50. Any method on an offshore platform to collect and direct liquid hydrocarbons
to a safe location is named
a.
b.
c.
d.
Liquid overflow
Containment
Atmospheric Service
Vent
M3.9.a.9