Document Number: 501 Current Rev: 12/7/2020 Prepared by Gregory Thorn Review Cycle 3 years Manager Approval: MOC HSE 20-16 Revision No. Revisions noted in italics Page 1 of 28
HEALTH AND SAFETY PROCEDURE 501 - Work Permit
1.0 PURPOSE
Westlake Geismar has developed this Work Permit Program to eliminate potential accidents, injuries, and to enhance employee protection.
To provide for maximum personnel safety in the plant, any work performed in the operating areas must have prior approval of Permit Issuer in charge of the area involved before performing work. Permits are issued by a Permit Issuer to the Permit Receiver after performing a risk review and discussion at the jobsite and verifying that appropriate precautions have been taken.
2.0 SCOPE
The Work Permit Program applies to servicing and maintenance of process equipment and machinery, including hot work, hot taps, excavation, confined space entry, scaffold erection etc., at Westlake Geismar.
Permits will not be required in maintenance shops or designated fabrication areas.
Permits are not required when performing work in control rooms, offices, or similar buildings unless electrical work is performed.
Permits are required outside unit boundaries where excavations or electrical work is performed.
This program does not apply to any operational or maintenance activities conducted by operations personnel. Operations does not permit Operations. Operations manages their activities through Standard Operating Procedures or risk assessments.
3.0 DEFINITIONS
3.1 Affected Employee - Employees impacted by the performance of permitted work which may include hot work
3.2 Authorized Employee - Employees trained and authorized to perform permitted work in the plant
3.3 Cold Work - Any servicing, opening, or maintenance of process equipment and machinery. Cold work does not involve any hot work, hot
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Document Number: 501 Current Rev: 12/7/2020 Prepared by Gregory Thorn Review Cycle 3 years Manager Approval: MOC HSE 20-16 Revision No. Revisions noted in italics Page 2 of 28
HEALTH AND SAFETY PROCEDURE 501 - Work Permit
taps, excavations, and/or confined space entry.
3.4 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.
3.5 Craft-specific PPE - PPE required to perform the specific permitted maintenance task and is determined by the personnel performing the task.
3.6 Equipment Owner - The person assigned to an area / department that normally controls and or operates the equipment.
3.7 Hot Tap - (see HSP-506_3 Hot Tap Checklist)
3.8 Hot Work - (see HSP-504 Hot Work)
3.9 Incipient Fire - A fire which is in the initial or beginning stage and which can be controlled or extinguished by a portable fire extinguisher or other simple means.
3.10 Joint Job Walk (JJW) – a meeting that is held by the operator (permit issuer) and the worker (permit recipient) that is conducted at the job location where the work is to be performed. The goal of the JJW is to identify all hazards and perform a detailed review of the work to be performed and mitigate and manage each hazard to avoid an incident during the performance of the task.
3.11 Operator Assisted Work - Work directed by Operations with maintenance assistance.
3.12 Permit Issuer - Westlake employee who has been identified by Unit Manager and completed Work Permit Certification.
3.13 Permit Recipient - Westlake Employee or Contractor who have completed Westlake Geismar’s Permit Recipient Training and have been identified by their company as Permit Recipient.
3.14 Permit Work Area PPE - PPE required by any employee performing the permitted work or any employee who comes in close enough proximity to the permitted work that they would be exposed to the hazards associated with the permitted work.
Printed controlled copy expires 24 hours after 1:12 PM on 7/15/2021.
Document Number: 501 Current Rev: 12/7/2020 Prepared by Gregory Thorn Review Cycle 3 years Manager Approval: MOC HSE 20-16 Revision No. Revisions noted in italics Page 3 of 28
HEALTH AND SAFETY PROCEDURE 501 - Work Permit
3.15 Stop Work Authority – A critical piece of a successful safety culture that provides employees and contract workers with the responsibility and obligation to stop work when a perceived unsafe condition or behavior may result in an unwanted event.
3.16 Unit Area PPE - PPE required by anyone entering the unit area and is designated by signs and/or line demarcations.
3.17 Work Permit - a multifaceted safety planning tool, to ensure that necessary safety precautions have been addressed prior to beginning work on site
4.0 RESPONSIBILITIES
Westlake Geismar has provided a Work Permit Program for employees and is responsible to train employees. Westlake Geismar is also responsible to notify contractors of the Work Permit Program. Specific responsibilities are listed below:
4.1 Health, Safety, & Environmental (HSE)
4.1.1 Train production and maintenance employees on the proper implementation of this program.
4.1.2 Responsible for the certification process for Permit Issuers and a qualification process for recipients.
4.1.3 Ensure that Work Permit procedures are reviewed at least every three years.
4.1.4 Maintain certification records.
4.1.5 Audit Contractor's compliance to this procedure
4.2 Permit Issuer
4.2.1 Maintain certification as Permit Issuer.
4.2.2 Issue appropriate Work Permit to qualified Permit Recipients when requested
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Document Number: 501 Current Rev: 12/7/2020 Prepared by Gregory Thorn Review Cycle 3 years Manager Approval: MOC HSE 20-16 Revision No. Revisions noted in italics Page 4 of 28
HEALTH AND SAFETY PROCEDURE 501 - Work Permit
4.2.3 Perform atmospheric monitoring as required by the permit
4.2.4 Indicate required personal protective equipment necessary for the Unit and permit work area on all permits (Use Appendix C - PPE matrix when necessary)
4.2.5 Conduct a hazard assessment at the Job Site of the work to be performed and the work area to identify all hazards associated with the area and the work to be performed.
4.2.6 Facilitate Joint Job Walk with Permit Recipient
4.2.7 Periodically monitors work area to ensure permit requirements are being followed.
4.2.8 Review work area after the job is complete to ensure work area is clean and safe to be put back in service.
4.2.9 Authorize and document any Verbal Authorization tasks on the Work Authorization Log.
4.2.10 Clearly communicates to permit recipients the right and responsibility for stop work authority.
4.3 Permit Recipient
4.3.1 Complete “Permit Recipient” Training and follow the requirements in this procedure.
4.3.2 Receive the permit from operations
4.3.3 Review the Work Permit with the work crew, verifying their understanding, and ensure all workers are accounted for on the work permit by signature
4.3.4 Conduct Joint Job Walk with crew
4.3.5 Ensure that work crew follows plant requirements, including specifications outlined in the Work Permit.
4.3.6 Ensure work area is clean and safe before turning it over to operations.
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Document Number: 501 Current Rev: 12/7/2020 Prepared by Gregory Thorn Review Cycle: 3 years Manager Approval: MOC HSE 20-16 Revision No. Revisions noted in italics Page 5 of 28
HEALTH AND SAFETY PROGRAM 501 – Work Permit
4.3.7 Meet with operations to close out the permit.
4.3.8 Immediately escalate all incidents or change in conditions to Operations.
4.3.9 Communicate “Stop Work Authority” to crew.
4.3.10 Facilitate a JSA with work crew for work to be performed
4.4 Work Crew
4.4.1 Learn, understand, and follow this program.
4.4.2 Review and document their acceptance by signing the permit legible.
4.4.3 Comply with all permit requirements.
4.4.4 Ensure work area is clean and safe before turning it over to operations.
4.4.5 Immediately report any incident or change in conditions to the Permit Recipient
4.4.6 Utilize “Stop Work Authority” when conditions change to the point to creating unsafe condition or at-risk behavior.
4.4.7 Participate and sign JSA for work to be performed.
5.0 PROCEDURES
After checking to see that necessary precautions have been considered and that correct procedures will be followed, Permit Issuer completes the Work Permit and issues it to the personnel performing the work. A quick reference checklist to help explain how to properly fill out the permit is shown in Appendix C.
The Work Permit is a multi-faceted permit. This permit is primarily used for routine maintenance and repair work, process opening, and hot work. If additional permits/checklists are required, they will be specified on the Work Permit.
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Document Number: 501 Current Rev: 12/7/2020 Prepared by Gregory Thorn Review Cycle: 3 years Manager Approval: MOC HSE 20-16 Revision No. Revisions noted in italics Page 6 of 28
HEALTH AND SAFETY PROGRAM 501 – Work Permit
5.1 Additional permits/checklists may include but not limited to:
5.1.1 HWPB 5.1.2 Hot tap 5.1.3 Excavation 5.1.4 Confined Space Entry 5.1.5 Energized Equipment
5.2 Documenting PPE
It is important to remember when filling out the permit the four different types of PPE classifications and documenting them correctly on the permit. They are as follows:
5.2.1 Work Area Entry PPE
Refers to basic PPE (Safety Toed Footwear, Cl2/Acid escape respirator, hard hat, safety glasses with side shields, hearing protection, gloves, googles on person, and Flame Resistant Clothing) to enter the work area.
This is communicated via site specific orientation, signs and the permit
5.2.2 Area Specific PPE
Refers to specific PPE required when entering certain areas. “Goggle-required” areas are identified by signs and/or diagonally painted stripes (Yellow and black).
The Area Specific PPE is communicated via site unit specific orientations, signs, and the permit.
5.2.3 Process Specific PPE
Refers to specific required PPE when conducting tasks that potentially expose workers to process hazards (supplied air respirator when opening up a vinyl process).
Process Specific PPE is communicated in the site unit specific orientation, Appendix C - PPE Matrix and permits.
Printed controlled copy expires 24 hours after 1:12 PM on 7/15/2021.
Document Number: 501 Current Rev: 12/7/2020 Prepared by Gregory Thorn Review Cycle: 3 years Manager Approval: MOC HSE 20-16 Revision No. Revisions noted in italics Page 7 of 28
HEALTH AND SAFETY PROGRAM 501 – Work Permit
5.2.4 Craft Specific PPE
Refers to specific PPE required by the contractor’s specialized craft. Examples #8 lens for certain types of welding; full face air purifying respirator with organic vapor cartridges when applying certain coatings
Contractors will identify the PPE and document on their JSA
Craft Specific PPE is not required to be documented on the permit.
5.3 Issuing the Work Permit:
5.3.1 Maintenance/contractors will request a Work Permit for any activities that meet the scope of this procedure.
5.3.2 Permit Issuer initiates all permits by documenting the following:
Date Time Issued Valid Until Work Order # (Or N/A if not applicable) Permit Issued To Scope of Work (be very descriptive) Equipment Name Equipment Number Equipment Service Nature of Work Personal Protective Equipment
5.3.3 If additional permits are required, they must be specified in the Nature of Work section.
5.3.4 Permits may be written for the duration of the shift. If the shift should overlap the Operations shift, the active permits must be communicated to the oncoming operation personnel. When responsibility for a permit for that permit duration is transferred to a new Permit Issuer, the current Permit issuer and Accepting Permit
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HEALTH AND SAFETY PROGRAM 501 – Work Permit
Issuer shall sign the field copy of the Work Permit to transfer responsibility. When the work is complete, the permit will be completed with a sign off by the oncoming Operations personnel.
5.3.5 The Permit Issuer continues the permit process by completing the following permit sections:
General Considerations Hot Work Considerations Atmospheric Monitoring Process Opening Section Comments
5.3.6 Field presence and situational awareness are critical to safe work – it is imperative that a Joint Job Walk with the Permit Recipient at the location of the jobsite is completed as part of the permit issuance to ensure that all necessary precautions have been taken prior to commencing work. At a minimum, the Joint Job Walk must address the following:
Communicate Westlake’s commitment to their safety.
Gauge the Permit Recipient’s commitment to ownership of their safety and those around them.
Ask open–ended questions concerning the work, hazard, and the mitigation to gauge their understanding.
Communicate the responsibility to escalate:
o Incidents, o Near Misses, o Injury, o Property Damage, o Exposures, o Change in job scope o Loss of primary containment (release to the environment) o Any other abnormal condition to operations
Review permit conditions, scope, and requirements.
Review the hazards and conditions of the immediate and
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HEALTH AND SAFETY PROGRAM 501 – Work Permit
surrounding work area.
Summary of the process overview citing any valves or critical equipment that they could impact while conducting their work.
The right and responsibility to activate “Stop Work Authority” – See section 5.5
The responsibility of the work crew to communicate and coordinate work activities with others in close proximity
Discuss the unit evacuation alarm, evacuation route, primary and secondary assembly points, and location of wind socks
Identify the location of nearest eyewash/safety shower. Activate to verify operability
Verify that changes to the Work Permit have been initialed by Issuer and Receiver
NOTE: If a change is made to the permit, everyone that signed off on the permit must be made aware of the change.
Ensure the Permit Recipient understands to stop work if permitted conditions or scope change, and notify the Permit Issuer
If applicable, use Isolation List to review Isolation Points and Zero Energy Points with authorized employees.
For electrical lock outs use Isolation List to review de- energization and demonstrate zero energy by testing start/stop switches.
For Process Openings identify Process Opening Points and/or Cut Points with authorized employees.
Verify special condition mitigations and/or contingency plans, specific to the work to be permitted, are in place and will effectively address the hazards they are designed to manage.
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HEALTH AND SAFETY PROGRAM 501 – Work Permit
Any other information that would ensure the safety of the work crew while working in the area.
5.3.7 Permit Issuer and Recipient signature must be completed in the field only after all job details and Joint Job Walk has been conducted. These signatures should be located in the Authorization and Permit Recipient section of the permit.
5.3.8 The Permit Recipient is given two carbon copies (yellow and tan). The original (white) is maintained by Operations.
5.3.9 The Permit Recipient retains the yellow copy, gives the tan field copy to the personnel performing the work, and instructs them on the job safety aspects and permit requirements.
5.3.10 The Permit Recipient must perform a Pre-Job Meeting communicating all details discussed during the Joint Job Walk.
5.3.11 Once the Permit Recipient instructs the work crew on all safety aspects and permit requirements, the work crew is responsible for signing the back of the tan field copy indicating their understanding and acceptance of the requirements.
5.3.12 If a crew member joins the work crew after the Pre-Job Meeting has been communicated, the crew member will be responsible for reading the permit and signing the back of the tan field copy indicating their understanding and acceptance of the requirements.
5.3.13 The tan field copy of the permit must be in the possession of the workers at the jobsite at all times.
5.3.14 When the job is complete or the Work Permit expires, the Permit Recipient or his designee with the tan field permit copy locates an Operations Representative and both will review the job site for safeness and cleanliness. The Permit Recipient and the Operations Representative sign the permit in the Permit Return section. Operations retains the tan field copy and returns it to the Control Room for retention.
5.4 Operator Assisted Work
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HEALTH AND SAFETY PROGRAM 501 – Work Permit
5.4.1 Work that is performed and directed by operations and assisted by maintenance without issuing a permit.
5.4.2 Operations must be present while the work is being performed and maintenance must be within line of site.
5.4.3 When operations is no longer directing the work or maintenance is no longer in the line of site, work must cease and a Work Permit must be issued.
5.5 Stop Work Authority
5.5.1 When an individual or group becomes concerned or uncomfortable with work conditions or with the way a job is proceeding from a safety or health prospective, then that individual or group can invoke Stop Work Authority. He or she does this by stopping work on the job and informing a Westlake employee or contract supervisor of the situation, so that steps can be taken to understand the risks and make plans to mitigate those risks. The steps in the process are as follows:
The concerned individual informs an employee or contract supervisor that they believe a safety or health risk exists and that a “Stop Work Authority” is warranted.
The employee or contract supervisor must immediately stop the work and contact the Permit Issuer.
The Permit Issuer who evaluated the job, identifies the additional identified risk(s), and works with all affected parties to mitigate the risk.
5.6 Updating Work Permit
5.6.1 Updating a permit will be accomplished by the Permit Issuer reviewing the work area and ensuring the conditions are still acceptable to perform the work.
5.6.2 The Permit Issuer must initial and note the time in the “update” blank of the Permit Authorization section.
5.6.3 The Permit Recipient must also initial and note the time in the
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HEALTH AND SAFETY PROGRAM 501 – Work Permit
“update” blank of the Permit Authorization section.
5.6.4 Updating Work Permits will be required for the following conditions:
Work Permit Exceeds Twelve hours – Permits can only be updated for one, twelve hour period. (Permits may only be valid for twenty-four hours. If twenty-four hours is exceeded, a new Work Permit must be issued)
Alarm Conditions – During a Plant Alarm event all active permits become void. This does not include our Wednesday test of our emergency alarm system. Following a Plant Wide All-Clear the permits must be reissued prior to work resuming.
Work Stoppage Conditions- Any time work is stopped for more than 30 minutes the permit issuer must update the Work Permit. (e.g. lunch break)
5.7 Nature of Work:
5.7.1 Cold Work includes:
Any servicing, process opening, or maintenance of process equipment and machinery.
Cold work does not involve any hot work, hot taps, excavations, and/or confined space entry.
Routine maintenance of process equipment and machinery.
5.7.2 Hot Work Permit
Hot work activities will be permitted using the designated sections of the Work Permit and follow the requirements of (HSP – 504)
5.7.3 Process Piping, Equipment and Vessel Opening
A Work Permit will be issued for all process opening activities.
See the HSP-507 “Safe Process Piping, Equipment & Vessel Opening Procedure” for specific details.
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Document Number: 501 Current Rev: 12/7/2020 Prepared by Gregory Thorn Review Cycle: 3 years Manager Approval: MOC HSE 20-16 Revision No. Revisions noted in italics Page 13 of 28
HEALTH AND SAFETY PROGRAM 501 – Work Permit
5.8 Additional Permit/Checklist Required
5.8.1 Hot Work on Pressure Boundaries (HWPB) / Hot Tap
A HWPB/hot tap checklist will be issued in addition to the Work Permit for all hot tap activities (see HSP-506 Hot Tap checklist).
5.8.2 Confined Space Permit
A confined space permit will be issued in addition to the Work Permit for all confined space work.
Entry into a confined space will be by permit only. This requirement will include entry by operations personnel for inspections or analysis, as well as for any other inspection by maintenance, contract, or vendor representative(s).
The confined space permit is an authorization and approval in writing that specifies the location, and type of work to be done. It also certifies that all existing hazards have been evaluated and necessary personal protective measures have been taken by the qualified person. (See HSP-503 Confined Space Entry Program.)
The Confined Space Name shall be added to the Work Permit in the “Nature of Work” section of the Permit.
5.8.3 Excavation Permit
In addition to the Work Permit, all excavation work must be conducted in accordance with HSP-508_1 Excavation Approval Form
5.8.4 Energized Equipment
When electricians will be working on or near energized equipment the Energized Equipment designation must be checked in the Additional Permit section.
See HSP-505 Lockout/Tagout for specific details regarding working on or near energized equipment.
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Document Number: 501 Current Rev: 12/7/2020 Prepared by Gregory Thorn Review Cycle: 3 years Manager Approval: MOC HSE 20-16 Revision No. Revisions noted in italics Page 14 of 28
HEALTH AND SAFETY PROGRAM 501 – Work Permit
6.0 TRAINING
6.1 Permit Issuers shall be qualified through a Permit Issuer Certification process. Frequency of training shall be as follows:
6.1.1 Initial training 6.1.2 Whenever changes are made to the procedure 6.1.3 When the Permit Issuer shows deficiencies
6.2 Permit Recipient shall be qualified through the Westlake Geismar Permit Recipient Training.
6.3 Fire watches will be trained and qualified in incipient fire extinguishing procedures and OSHA 29 CFR 1910.252.
6.4 Employees will be re-trained in the Work Permit Program for any updated procedures or whenever changes in job assignment or process equipment and machinery occur.
6.5 Retraining will be conducted whenever a periodic inspection reveals that employees are not fully aware of, or are not following established procedures, or if regulatory requirements change.
7.0 RECORDKEEPING
7.1 HSE department will maintain employee training records.
7.2 Permits will be kept by Operations for one week following work completion by each department.
7.3 If an incident occurs, permits associated with the incident will be given to the investigation team for processing and kept indefinitely.
7.4 This procedure will be controlled in http://gvcdocs.
8.0 REVIEWS
8.1 The Westlake Geismar Work Permit Program will be reviewed at least every three years. HSE will ensure this review is performed. The purpose is to assess compliance, to ensure that all employees who should be included are, and to evaluate program effectiveness.
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Document Number: 501 Current Rev: 12/7/2020 Prepared by Gregory Thorn Review Cycle: 3 years Manager Approval: MOC HSE 20-16 Revision No. Revisions noted in italics Page 15 of 28
HEALTH AND SAFETY PROGRAM 501 – Work Permit
8.2 The review includes:
8.2.1 The current Work Permit Program 8.2.2 Employee training records 8.2.3 Work Permit practices; 8.2.4 Employee awareness; and 8.2.5 Contractor awareness
8.3 Following the review, the Work Permit Program will be revised to include any necessary changes. Review results will be documented. All employees will be informed of any changes made in the plan.
9.0 REFERENCES
Occupational Health and Safety Administration's 29 CFR 1910.119 (August 26, 1992). "Process Safety Management of Highly Hazardous Chemicals."
Occupational Health and Safety Administration's 29 CFR 1917.152 (July 5, 1983). "Welding, Cutting and Heating (Hot Work)."
10.0 APPENDICES
Appendix A - Work Permit
Appendix B - Work Permit Step by Step Instructions
Appendix C – PPE Matrix
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APPENDIX A
WORK PERMIT
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FRONT OF WORK PERMIT
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BACK OF WORK PERMIT
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APPENDIX B
Work Permit Step-by-Step Instructions
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FRONT OF WORK PERMIT
3 1 2 4 6 5 7
8 9 10
11 12
13
15 14
16
17
18
19
21
20
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Front Side of Work Permit Checklist
1. Date of Work
2. Time work starts.
3. Time shift is complete.
4. Write the Unit Name
5. Specific area within Unit
6. Write contractor name.
7. Be as specific and descriptive as possible.
8. Worker order number or N/A
9. Name of what is being worked on.
10. If no number is available write N/A.
11. Nature of Work section. Select the appropriate Nature of Work for this work
12. Additional Permit/Checklist Required. Select if any are applicable
13. Check all appropriate boxes for the job. If any chemicals could be a potential exposure, utilize the PPE Matrix and circle the appropriate PPE. Explain the type of protective equipment.
14. General Considerations. Each box should be checked individually. No straight lines drawn vertically.
15. Level 1 High Energy Hot Work Considerations. Each box should be checked individually. No straight lines drawn vertically.
16. Write which toxicity test was run. Must have full last name in signature block – not just initials. a. Entries must be legible (print if necessary). b. Signature must include last name. (First initial OK, but must spell out your last name).
17. This section is dedicated to Process Opening. It allows for documentation of barricaded area, identification of process opening points, Line Opening Field Review, the CPC, and downgrade of PPE.
18. Chemical Hazards associated with this job
19. Permit issuer to print name and then sign underneath for authorization. Operations retains the white copy. Comment section is to explain the reason for picking “no” in the “General or Hot Work Considerations” sections of the permit.
20. Transfer of Authority. If Permit Issuer changes, document transfer on all copies of Permit.
21. This space is for the signature of the Permit Recipient (Permit Recipient in most cases) and the time the permit was received.
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BACK OF WORK PERMIT
23
24
25
26
27
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BACK SIDE OF WORK PERMIT
22. Must have signatures of all workers and in a legible fashion. [Print name if necessary, to be legible]
23. Fire watch must continue to monitor for 30 minutes after the last spark has been made.
24. This area for additional monitoring if needed. If used remember to write down specific toxicity test that was used.
25. This is very important to get the proper exchange between operations and maintenance to understand the status of the equipment or job that was performed. Signature in this box says that area is clean and safe condition, additionally a yes or no needs to be checked. If no is checked an explanation must be explained in the comments section.
26. Remember that once you sign here you have accepted the job and area are in pre-work condition. This needs to be done in the field.
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APPENDIX C
PPE Matrix
Chlor-Alkali Unit PVC Unit VCM Unit Bio Unit
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APPENDIX C – Chlor-Alkali Unit PPE Matrix
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APPENDIX C – PVC Unit PPE Matrix
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APPENDIX C – VCM Unit PPE Matrix
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APPENDIX C – Bio Unit PPE Matrix
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