Maintenance confined spaces

Will procedures change for hot work, opening process lines, work on energized electrical equipment, blinding before maintenance, confined space, etc ... 

F. All site control elements of the safety and health program must be fully implemented as described in the program. The purpose of site control requirements is to ensure that only properly trained and authorized individuals enter those areas of the site with potential hazards, and that, in the event of an emergency, rapid assistance can be rendered to employees working in the exclusion zone. This section discusses the findings of two components of site control the establishment and maintenance of site work zones and the establishment and implementation of appropriate confined space procedures. 

The contractors SSAHPs at Sites B, F, and K had general confined space provisions but lacked site-specific confined space procedures. For example, SSAHPs for the Site K contractor and subcontractor had written confined space entry programs, but the programs did not establish site-specific rescue procedures or identify the confined space hazards present on the site. The job hazard analyses for both programs failed to address site maintenance tasks that could involve confined space entry and hot work hazards. The programs also failed to identify the specific person or position responsible for supervising confined space entry procedures and the location of permit-required confined spaces on site. Interviews with both contractors indicated confusion about rescue procedures. 

Safe work practices for hazards control lockout/tagout, confined space entry, procedures for opening process boundaries and entrance control for maintenance... 

No maintenance task can be issued without the person responsible for controlling the workforce establishing that the work is to be carried out safely. Areas where this is essential would include boilers, pressure systems, electrical systems, confined spaces, hot work, deep sumps/shafts, tanks, and lone working. 

Steam drums (top drums) often are difficult to enter or move around in because of the fixed mechanical equipment contained within the confined space. It should not be assumed that this equipment has always been correctly reinstalled after any previous inspection or maintenance programs. Consequently, steam drums should first be inspected for proper location, orientation, and anchoring of steam separators, FW lines, baffles, continuous BD lines, and chemical injection lines. 

Permit-to-work systems See under Maintenance Entry into confined spaces (e.g. vat, vessel, flue, sewer, boiler or similar) Use of non-flameproof electrical equipment where flammable liquids/ vapours/dusts may arise... 

Finally, PMCD work permits must be issued for all entries into chemical agent hazard areas and areas designated Permit Required Confined Spaces. Work permits, which must identify the individual and the work to be performed, are reviewed by operations maintenance and safety personnel and approved by the shift manager. Special monitoring may be required, and records of entries and monitoring must be kept for 30 years beyond the last day of employment or the closure date of the facility. 

Maintenance must sometimes be performed at elevated heights, within confined spaces, and in situations with challenging ergonomic conditions. Opening equipment that has not been properly prepared may have potential to release chemicals or electrical or mechanical energy. Hazards that exist in other parts of the process could be transported to areas where maintenance is underway, if the systems have not been suitably isolated or fully cleared of residual chemicals. 

Supportive safety procedures are utilized to ensure that there are necessary controls in place for safe maintenance and repairs that importantly includes nonroutine hazardous work. These procedures encompass rules governing lockout and tagout, confined space entry, elevated work, electrical work, etc. The committee found some minor problems in these supportive procedures and differences among the sites, especially when some of the work is done by subcontractors, who may have their own practices. 

The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout confined space entry opening process equipment or piping and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees. 

Nomoutine work which is conducted in process areas needs to be controlled by the employer in a consistent manner. Hie hazards identified involving the wmk that is to be accomplished must be communicated to those doing the work, but also to those operating personnel whose work could affect the safety of the process. A work authorization notice or permit must have a procedure that describes the steps the maintenance supervisor, contractor representative, or other person needs to follow to obtain the necessary clearance to get the job started. The work authorization procedures need to reference and coordinate, as applicable, lockout/tagout procedures, line breaking procedures, confined space entry procedures, and hot work authorizations. This procedure also needs to provide clear steps to follow once the job is completed in order to provide closure far those that need to know the job is now completed and equipment can be returned to normal. 

As well as understanding the profile of the person(s) who will be using the procedures, it is also important to understand the physical and social context in which the manual will be used. For example, operators and maintenance technicians often work outside, where they have to contend with high or low temperatures, wind, rain, and snow. If they work indoors noise and confined space access could be an issue. The operating and maintenance manuals should be written and pubUshed in a manner such that it is useful to the operator in his or her workplace. 

Maintenance work is, by its very nature, hazardous. Workers maintain equipment that is opened or disassembled, thereby exposing those workers to a wide range of potential hazards that stem from toxic chemicals, heat, electricity, moving machinery, hydraulics, pneumatic equipment, falling objects, springs and coils, and falls from equipment. In addition, maintenance workers may be asked to work at heights, in confined spaces, or in other unsafe locations. Therefore, first goal of any maintenance procedure is to ensure that the work can be carried out safely. 

There are three permit systems very common to the petrochemical and refining industries because OSHA mandates them. They are confined space, lockout/tagout, and hot work. All process employees—operators, instrument technicians, analyzer technicians, and maintenance personnel—sooner or later participate in a permitting situation. 

Work outside the normal routine needs special management control. This requires formal procedures, carefully followed, for such things as confined space entry, hot work, and line breaking and equipment opening. The procedures should cover the activities of operators, plant maintenance workers, contractors, and any others who may become involved. Written documents should spell out responsibilities, approval mechanisms, tagout procedures, and methods for verification of proper completion. 

Noisy machinery is sometimes placed inside a small containment building or acoustic enclosure. Acoustic enclosures may be either of the close fitting or walk-in (large) type. The use of acoustic enclosures is generally not a preferred solution to noise problems because they create a confined space and have the potential for a buildup of a flammable or explosive cloud should the equipment leak. Also, the containment structure is likely to make maintenance and inspection more difficult (a confined space entry will be required), and it will increase the size of the equipment s footprint. 

Before people enter a confined space suitable and sufficient emergency and rescue arrangements must be in place. These arrangements must reduce the risks to rescuers so far as is reasonably practicable and include the provision and maintenance of suitable resuscitation equipment which must be designed to meet the specific risks associated with the particular confined space. 

Are all of the applicable Work Permit Procedures (Confined Space Entry, Lock Out/Tag Out, Hot Work, High Work, etc.) in piace Have the Operating, Maintenance and Supervisory personnel been properly trained on the Work Permit Procedures ... 

SB-15 Avoiding Hazards in Confined Work Spaces During Maintenance, Construction and Similar Activities. Guidelines for protecting personnel working in confined spaced (2 pages). 

The equipment provided for use by backup personnel should be covered by the maintenance manual and work permits. Such equipment includes the protective equipment necessary for entry and the gear required for rescue of personnel from the confined space. The latter includes chain falls, lifelines, and harnesses. These devices must be securely fastened outside the space. The best choice will depend on the shape of the access port(s). In the case of a closed vessel provided with one or more manways, for example, a wrist harness may be preferable to a full-body harness. The latter may make it very difficult to remove a person who is badly injured or unconscious. 

Portable analysers are available which measure the concentration of oxygen in the air by the depolarisation produced at a sensitive electrode mounted in the instrument Figure 3.3.11). Several different devices are available which vary in sensitivity, reliability and ease of maintenance but they must all be checked and carefully calibrated to the manufacturers instructions before use. Long extension probes may be attached which allow remote inspection of confined spaces. 

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