Geo Fossil Fuels Tabula Rasa Energy Perdure Petroleum
Health, Safety and Environmental Policy
Geo Fossil Fuels Tabula Rasa Energy Perdure Petroleum HEALTH, SAFETY & ENVIRONMENTAL (HSE) POLICY
Revised 9/1/19
INTRODUCTION
Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum and each of its subsidiaries (collectively referred to herein as the “Company” or “Tabula Rasa Energy”), considers the health and safety of its employees to be one of the most important phases of its operation. The Company's HSE Policy is to maintain a work environment that is safe for all employees and conducive to attaining high work standards.
All safety rules and guidelines are based on recognized safe practices, standards, federal, state and local laws and regulations and industry recommended practices. Every employee is responsible for compliance with the Company's safety requirements, and their full cooperation is necessary for accident prevention and loss control.
The prevention of accidents is of the utmost importance. Anyone who becomes aware of a potential hazard is expected to attempt to correct the hazard, if possible, and report the hazard to their supervisor.
No illegal drugs are allowed on the facilities operated or contracted to the Company. Illegal drugs include marijuana or any other substance which the possession or use is unlawful. Also, anyone who reports for work under the influence of alcoholic beverages, stimulants, depressants, hallucinogens, or other drugs which could endanger the person or others will not be permitted to work.
As a further safety precaution, entry into or upon Company's sites is conditioned upon the Company's right to search the person and personal effects of the entrant for illegal drugs. These searches may be made without prior warning and may include lockers and rooms at any work area operated by the Company, if appropriate. Such prohibited items discovered through these Company searches may be taken into custody and, if appropriate, may be turned over to the proper law enforcement authorities.
The Company prohibits the possession, use or distribution by employees of firearms, explosives or weapons of any kind while on Company sites (including all concealed handguns regardless of whether the employee has been issued a concealed handgun license).
Violation of the policies and procedures defined herein will be cause for disciplinary action up to and including immediate discharge/termination or cancellation of contractual services.
Unless otherwise specified, for purposes of this Policy:
1. The term “site” shall mean a Company office and/or field location.
2. The term “site supervisor” shall mean the senior employee for a particular activity at a Company site.
3. The term “Senior Safety Officer” shall mean the Senior Vice President of the Company or his designee.
4. MANAGEMENT RESPONSIBILITY
To ensure compliance with the policies and procedures of the Company, the managers and supervisors are charged with the responsibility for assuring safe practices by all Company employees under their supervision. The managers and supervisors also have the responsibility for being familiar with the documentation and reporting requirements as outlined in Section 5, Accident/Injury Investigation and Reporting.
The managers and supervisors are expected to give the same high level of personal attention to the HSE Policy that is devoted to other supervisory responsibilities.
It is the managers’ and supervisors’ responsibility to see that the Company site is operated in a safe manner, to protect the employees from hazards, and safeguard against property losses from fire, storm or other perils. The managers and supervisors are the individuals that the Company will ultimately rely upon to assure an effective HSE Policy.
The managers and supervisors have the responsibility of translating safety policies into a set of on-the-job practices which must then be enforced. These practices include development of safe working procedures through training and supervision of the employees. These individuals are also responsible for the prompt correction of all recognized hazardous conditions, work methods, and practices within their area. Each supervisor is responsible and accountable for their performance in this safety function as well as their performance in other work related areas.
Managers and supervisors will identify and discuss any observed violations with the employee. Any recommended disciplinary action will be documented and forwarded to the Company Senior Safety Officer.
The Occupational Safety and Health Act of 1970, Section 5(a) states:
”Each employer has the general duty to furnish each of their employee’s employment and a place of employment free from recognized hazards causing, or likely to cause, death or serious physical harm; and the employer has the specific duty of complying with safety and health standards promulgated under the Act."
EMPLOYEE RESPONSIBILITY
The employee's responsibility is to understand and comply with the principles of the HSE Policy. Each employee is expected to abide by and support all rules, standards and policies outlined in the HSE Policy. Failure to comply with these policies and procedures will lead to disciplinary action.
According to the Occupational Safety and Health Act of 1970, Section 5 (b):
"Each employee has the duty to comply with safety and health standards and all rules, regulations and orders issued pursuant to this Act which are applicable to their own actions and conduct."
CONTRACTORS
All contractors working on Company sites should have a valid Master Service Agreement (MSA) or equivalent contract with the Company. The Company shall make a copy of the Company's HSE Policy available to contractors, and will furnish details for the particular operation planned before work commences. Site specific hazards shall be identified during facility/field orientation and/or check-in. All contractors and contractors’ personnel are expected to adhere to the Company’s policies.
All contractors and contractors’ personnel at Company sites should be fully trained and currently qualified for their job in accordance with safety and environmental related regulatory and industry standards.
All contractors and contractors’ personnel must understand their responsibilities relative to safety and environmental issues. All contractors and contractors’ personnel are expected to comply with all Company and governmental (federal, state, and local) safety and environmental guidelines, including but not limited to OSHA.
COMMUNICATION
Communication between management and employees is imperative with regard to health, safety, and environmental issues. It is the Company's responsibility to communicate potential hazards of the workplace to employees and it is the employees' responsibility to communicate the occurrence of avoidable hazards and hazardous situations to management without fear of repercussion. Communication can occur in a number of both visual and verbal formats.
1. OSHA workplace posters should be displayed in prominent locations where all employees can see them. Emergency phone numbers should be posted. In areas which require the posting of warning signs, the signs should be placed where they can be easily seen by employees and contractors.
2. Each employee will have access to or a copy of the latest edition of the HSE Policy and any future amendments. In addition, the most current version of the HSE Policy, including any amendments or changes, will be available at the Company’s office locations and on the Company intranet.
3. The Company will hold safety meetings.
POLICY AUDIT
The Company’s HSE Policy will be evaluated on a continuous basis, and routine audits will be conducted to maintain effectiveness and conformance with the Company’s operations and changes in industry and regulatory standards.
The most widely accepted way to identify hazards and potential non-compliance is to conduct safety and health inspections. The Company is responsible for the formulation of self-inspection procedures and checklists necessary to identify and correct potential hazards or unsafe practices. The HSE Policy will be administered by the Operations Department.
HSE inspections will be conducted at each facility. Inspections will be performed by the Operations Department or their designee, and the results of each inspection will be documented.
The Company HSE Policy will be reviewed, at least, annually for overall effectiveness. Records of these reviews will be maintained, and any necessary changes will be implemented. Any amendments or exceptions to the HSE Policy will require approval by the Senior Safety Officer.
POLICY EXCEPTIONS
Exceptions to the HSE Policy may be granted on an infrequent basis under extraordinary circumstances and will require, at a minimum, a joint evaluation and approval by the Senior Safety Officer and Chief Executive Officer with advice from the Company’s outside legal counsel.
When an exception is granted, additional mitigating measures shall be instituted to account for:
1. public safety;
2. the safety of Company employees;
3. the safety of Contract personnel; and
4. protection of the environment.
The exception request, any mitigating measures, and appropriate contracts and approvals shall be documented and maintained by the Operations Department.
DISCLAIMER REGARDING HSE POLICY
This HSE Policy is intended to cover all current and future potential operations of Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum. As a result, specific sections of this Policy and various manuals, policies, programs and plans referenced in this Policy may not be applicable at this time and shall only be developed and applicable if the Company or a specific site becomes subject to this requirement (e.g. NORM, Facility Response Plan, SPCC, etc). In addition, training will be targeted to specific locations based on requirements.
Employee’s Acknowledgement of Receipt & Acceptance of Policies/Procedures
I hereby acknowledge receipt of the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Health, Safety, & Environmental (HSE) Policy containing the currently effective Company HSE policies and procedures.
I understand that it is my responsibility to become aware of the contents of this Policy and that I have the opportunity to ask questions about any policy or procedure that is unclear to me. I further understand that the policies and procedures set forth herein may be altered or amended by the Company at any time, with or without notice.
Employee Printed Name Employee Signature Date
CONTENTS
1. SAFETY TRAINING ...... 1
2. OFFICE SAFETY ...... 3
3. SITE SAFETY AND SECURITY ...... 8
4. SITE EMERGENCY RESPONSE AND EVACUATION ...... 10
5. ACCIDENT / INJURY INVESTIGATION AND REPORTING ...... 15
6. FIRST AID ...... 21
7. PERSONAL PROTECTIVE EQUIPMENT (PPE) ...... 22
8. HAZARD COMMUNICATION (HAZCOM) ...... 31
9. LOCKOUT/TAGOUT (LOTO) ...... 33
10. CONFINED SPACE ...... 38
11. HOT WORK ...... 41
12. SAFE WORK OPERATIONS ...... 48
13. SHORT SERVICE EMPLOYEE (SSE) ...... 50
14. DRILLING AND WORKOVER RIG SAFETY ...... 51
15. EXCAVATION, TRENCHING AND SHORING ...... 52
16. FIRE SAFETY ...... 56
17. CARBON DIOXIDE (CO2) SAFETY ...... 64
18. HYDROGEN SULFIDE (H2S) SAFETY ...... 68
19. ELECTRICAL SAFETY ...... 70
20. MATERIALS HANDLING ...... 81
21. NATURALLY OCCURRING RADIOACTIVE MATERIAL (NORM) ...... 94
22. TOOL SAFETY ...... 96
23. VEHICLE OPERATIONS ...... 104
24. EXPOSURE CONTROL – BLOODBORNE PATHOGENS ...... 114
APPENDIX 1: PROGRAMS
3. ACCIDENT AND INJURY REPORTING 4. CONFINED SPACE PROGRAM 5. DRUG & ALCOHOL TESTING POLICY 6. EMERGENCY RESPONSE TEMPLATE 7. HAZCOM PROGRAM 8. HEARING CONSERVATION PROGRAM 9. HOT WORK POLICY FOR GFF PERDURE TABULA RASA 10. HYDROGEN SULFIDE (H2S) SAFETY POLICY 11. JSA SAFE WORK PERMIT 12. LOCKOUT-TAGOUT (LOTO) PROGRAM 13. PPE PROGRAM 14. RESPIRATORY PROTECTION PROGRAM 15. SPCC ANNUAL TRAINING 16. SSE PROGRAM
APPENDIX 2: FORMS
• PERDURE TRP INITIAL INCIDENT REPORT FORM • NEAR MISS INVESTIGATION FORM • PERDURE_TRP_DRIVER’S VEHICLE ACCIDENT REPORT • MVA (Motor Vehicle Accident) GUIDE • MVA GUIDE WITNESS STATEMENT REPORT • LOCK-OUT / TAGOUT FORM • PERDURE TRP SAFE WORK PERMIT_JSA • SAFETY MEETING ATTENDANCE LIST
1. SAFETY TRAINING
I. PURPOSE/SCOPE
The Company is continually designing and implementing training programs which are necessary for the health and safety of its employees. The goal of the HSE training program is to promote a safe working environment free of recognized hazards.
II. GENERAL POLICY
A. Safety training will be provided to employees to meet the requirements of the HSE Policy where applicable to the employee’s job.
B. Training will be made available to each employee with consideration given to work schedules. In certain circumstances, employees may be required to attend training programs on non-scheduled work days and will be compensated on such occasions.
C. Documentation of training will be maintained by the Operations Department or at each work location. These records shall include at a minimum, attendance at, subject of, date of, and location of training.
III. SAFETY INSTRUCTION
A. Safety information may be communicated via:
1. HSE Policy;
2. new hire orientations;
3. safety meetings;
4. training videos;
5. online and computer based training;
6. classes/seminars;
7. apprenticeships; and
8. mailings.
B. Training that requires certification will be conducted by authorized instructors.
12-2017 Page 1 of 114
C. Contractors are responsible for training their employees to perform the job for which they are hired as required by federal, state, and local laws and regulations. Additionally, contractors may refer to available Company safety information.
12-2017 Page 2 of 114
2. OFFICE SAFETY
I. PURPOSE/SCOPE
The scope of this section applies to general hazards in an office environment.
II. SAFETY EQUIPMENT AND PROCEDURES
A. Keep current emergency phone numbers for police, fire and medical aid near the telephone. Dial 911 where available.
B. Become familiar with all exits and building evacuation procedures. An evacuation plan should include both primary and secondary escape routes.
C. A first aid kit meeting the requirements of Section 6, First Aid, shall be made readily available in each office. Employees should know where the first aid kit is located. Employees should also know who has been trained in first aid and cardiopulmonary resuscitation (CPR) procedures and where these people are located.
D. AED’s may be provided at certain Company locations. Employees should be familiar with the location of the AED at their site.
III. EMERGENCY RESPONSE PROCEDURES
A. Refer to site specific Emergency Response Plan for detailed information.
B. In the event of a fire, call 911 and activate the alarm system.
C. Upon the sounding of the fire alarm, all employees shall immediately evacuate the building in accordance with the site specific Emergency Response Plan.
D. Do not use the elevators. Use the stairways to exit.
IV. OFFICE FURNITURE AND EQUIPMENT
A. Files and Cabinets
1. Do not overload the upper drawers and have only one drawer open at a time.
12-2017 Page 3 of 114
2. Close desk and file cabinet drawers when they are not in use. Never leave an open drawer unattended.
3. Avoid placing cabinets and files so that open drawers block passageways.
4. Never stack separate file cabinets unless they are designed to be stacked and can be fastened together.
5. Do not stack bookcases or file cabinets on tops of tables or desks unless designed for such use. Even if bolted to a wall, they may fall if the table is moved because of excessive unsupported weight.
6. Never climb on shelving, file cabinets, or furniture as it may topple over.
B. Other Furniture
1. Always use an approved ladder or step stool to reach articles high above the floor. Never use a swivel chair or other makeshift device to reach high places.
2. Sharp burrs on metal furniture, splintered edges on wooden furniture, poor casters and broken chairs should be repaired or replaced. Glass desktops are not recommended and should be removed when broken.
3. Avoid storing heavy objects above eye level in the office.
4. Secure pictures and wall hangings with the proper fasteners.
5. Desk chairs should be stable and level. Do not lean too far on a tilt back chair. Always keep one foot on the floor. Never lean back in a straight chair.
6. Make aisles wide enough for easy passage and always keep them clear of obstructions.
V. OFFICE INCIDENTALS AND MECHANICAL DEVICES
A. Care should be taken when handling office supplies. There are several hazards that are associated with office supplies such as paper cuts, sharp edges, pinch points, chemicals (ink, toner, etc.), and trip and/or slip hazards.
B. Use scissors and paper cutters with care. Paper cutters should be left in a closed and latched position when not in use.
12-2017 Page 4 of 114
VI. ELECTRICAL EQUIPMENT
A. Unplug all electrical devices when repairing or servicing.
B. Have worn electrical cords replaced promptly by employees who have been properly trained in accordance with Section 19, Electrical Safety. Never attempt electrical repairs yourself unless you are trained to do the work.
C. Keep walking areas clear of telephone and electrical cords. Tape down cords that temporarily cross aisles.
D. Electrical outlets should not be overloaded. Use only properly grounded three-pronged plugs or Underwriters Laboratories (UL) approved double- insulated appliances.
E. Do not plug, unplug or operate electrical equipment with wet hands.
F. Turn off the power overnight for coffee machines, desk lamps, stoves, and other non-essential electrical devices.
G. Keep liquids away from electrical equipment.
H. Shredders should be operated with extreme caution. Keep ties, dangling jewelry and loose clothing away from machines by standing to the side of the machine. Always stand in a position that is accessible to the "off" switch. Always turn off the machine after each use and do not force paper.
I. Have burned-out lights replaced promptly.
J. Immediately discontinue use of any office equipment that gives you a shock, makes a spark, or appears to be malfunctioning, and report all such incidents.
K. All electrical equipment should be used in accordance with local building codes.
VII. FLAMMABLE AND HAZARDOUS MATERIALS
A. Keep all flammable materials away from possible ignition sources and in approved containers with the contents labeled for identification. Containers must not be left uncapped.
B. Do not use aerosol sprays, cleaners or insect repellents near ignition sources.
C. Keep heat sources away from furniture and other flammable materials. Never block forced-air heater outlets.
12-2017 Page 5 of 114
D. Do not allow paper or other flammable material to accumulate near electrical equipment.
E. Do not use flammable liquids to clean electrical equipment.
F. Spilled liquid should be identified and removed immediately. Follow recommended safe-handling procedures if warranted.
G. Fumes or gases generated from equipment, such as ammonia gas from blue line reproduction machines, should be properly ventilated or exhausted.
H. Items not intended for use with stoves should not be placed on stove tops.
VIII. DOORS AND WALKWAYS
A. Observe the following safety tips for the opening of doors:
1. Open a door slowly, expect someone to be on the other side.
2. If a door opens toward you, approach it from the side.
3. When working alone, never carry items that prevent you from opening a door easily with a free hand.
B. Use the handrails on stairs.
C. Never run on stairs and always keep at least one hand free.
D. Keep doors, walkways and hallways clear of boxes and other obstructions.
E. Clearly mark all exits and have burned-out light bulbs replaced in exit signs promptly.
F. Report and/or remove all tripping hazards.
IX. PERSONAL SAFETY
A. Use caution when wearing high heels or hard heels that may be hazardous on slippery floors or stairs. Shoes should be kept on in the office except in approved special circumstances.
B. Dispose of broken glass and other sharp items in properly marked containers. Never throw loose glass pieces into a wastebasket.
12-2017 Page 6 of 114
C. When changing paper or removing paper jams, avoid touching the heated parts of copying machines or printing machines. Never stick a metal object such as a letter opener into a machine.
D. Close the cover on the copying machine during use to prevent eye injury caused by intense light.
E. When moving objects, lift or lower using the legs and not the back. Seek assistance when moving heavy objects. Be especially cautious of objects in high places or with an awkward shape.
12-2017 Page 7 of 114
3. SITE SAFETY AND SECURITY
I. PURPOSE/SCOPE
The purpose of this section is to establish basic standards for safety and security at all Company field locations.
II. GENERAL POLICY
A. Visitors to Company field locations shall go through a site specific introduction or orientation process that points out Company policies and potential hazards.
“Visitors” shall mean:
1. all employees, whether or not regularly stationed in the field, who are unfamiliar with the field location; and
2. all non-employees invited, with permission, to enter the field location for their own benefit and/or for the benefit of the Company.
B. At a minimum, the site specific introduction or orientation should include the following topics:
1. review of the hazard assessment for the facility;
2. pre-entry briefing prior to initiating site activity;
3. explanation of facility alarms;
4. evacuation procedures and muster stations;
5. location of emergency equipment;
6. PPE requirements;
7. accident/injury/spill reporting procedures;
8. designated smoking areas;
9. answers to any questions by visitors.
12-2017 Page 8 of 114
C. Where required, site specific plans meeting applicable laws, regulations, and rules (e.g. SPCC, MSDS, H2S Contingency Plans, Emergency Response Plans, HAZWOPPER Plans, if applicable) shall be kept onsite.
III. FACILITY SECURITY
A. Federal, state, and local laws, regulations, and rules governing facility security (e.g., Homeland Security Act) will be followed.
B. Appropriate signage will be displayed at all facilities.
C. Where practical, gates and/or fencing will be installed at facility entrances. Where gates are installed, they shall remain locked when the facility is unattended.
D. Where practical, lighting will be installed at facilities.
E. Transfer valves shall be secured (e.g., padlocks, guards, fencing).
F. At certain facilities, a security services company or, preferably, off duty law enforcement personnel may be contracted to secure and/or patrol the facility. In such circumstances, security guards will only be authorized to patrol the facility and call 911 if they observe an incident. Unless expressly authorized by Senior Management, security guards shall not be armed. When Senior Management authorizes the hiring of an armed security guard, the security guard shall be licensed to carry a weapon as required by state law.
G. Any loss of, or damage to, Company equipment, property or materials due to theft or vandalism will be reported to the site supervisor.
12-2017 Page 9 of 114
4. SITE EMERGENCY RESPONSE AND EVACUATION
I. PURPOSE/SCOPE
This section provides emergency response procedures for a site emergency and/or evacuation. Examples of a site emergency are a fire, explosion, tornado, hurricane, blizzard, flood, medical emergency, spill (chemical, crude oil, produced water), or uncontrolled release of regulated gas (natural gas) or carbon dioxide (CO2) regardless of size or volume.
II. GENERAL POLICY
A. The Company will provide site specific Emergency Response Plans for each Company site. The site specific Emergency Response Plan will be kept at each site and made available to employees. In addition, the site specific Emergency Response Plans will be posted on the Company intranet. Site specific Emergency Response Plans will include the following elements:
1. procedures for reporting a fire or other emergency;
2. procedures for emergency evacuation, including the type of evacuation and exit route assignments;
3. where applicable, procedures to be followed by employees who remain to operate critical plant operations before they evacuate;
4. procedures to account for employees after evacuation;
5. procedures to be followed by employees performing rescue or first aid; and
6. name and job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan.
B. Where required or applicable, site specific Emergency Response Plans will include or reference the emergency procedures outlined in the Facility Response Plans (FRP), Operations, Maintenance, and Emergencies (OME) Manuals, H2S Contingency Plans, Hazardous Waste Operations and Emergency Response (HAZWOPPER) Plans and Spill Prevention, Control, and Countermeasures (SPCC) Plans.
C. For additional information about or for questions concerning the site specific Emergency Response Plans, employees may contact their supervisors or the Senior Safety Officer.
12-2017 Page 10 of 114
D. The Company will maintain an employee alarm meeting the requirements of 29 CFR 1910.165.
E. Upon the sounding of the of the employee alarm system, employees shall evacuate from the site in accordance with the evacuation procedures and maps provided in the site specific Emergency Response Plans.
F. Evacuation drills will be conducted at each site in accordance with the site specific Emergency Response Plan.
G. The Company may designate certain employees as “Team Leaders.” Team Leaders will be responsible for assisting in a safe and orderly evacuation of the employees in their team in the event of an emergency. In addition, Team Leaders may be responsible for those tasks described in the site specific Emergency Response Plan for their site.
H. Site supervisors will review the Emergency Response Plan with their employees when an employee is initially assigned to a job, when an employee’s responsibilities under the plan changes, when the plan is changed.
I. Employees are responsible for notifying their supervisor if an emergency situation arises, and employees are responsible for being familiar with Company emergency response procedures and practices.
J. Employees shall not discuss any incidents with anyone other than their supervisor/manager, the Senior Safety Officer or his designee or Company legal counsel.
III. TRAINING
Employees who respond to emergencies will receive appropriate training on an annual basis. Employees who respond to spills or the release of hazardous substances (including crude oil) will receive the appropriate training as required under 29 CFR 1910.120. Training will be documented and training records will be maintained by the Operations Department or at each work location.
IV. PLANNED RESPONSE ACTION/EMERGENCY ACTION CHECKLIST
A. Emergency Action Checklist
The internal and external alert procedures become effective immediately upon the observance of or hearing of any site emergency. An employee observing or receiving knowledge of such a site emergency will immediately take the actions specified in the site specific Emergency Response Plan and, where required, the FRP, OME Manual, H2S Contingency Plan, HAZWOPPER Plan or SPCC Plan, and notify the designated person as provided in the internal and external alert 12-2017 Page 11 of 114
procedures below. The priority in all circumstances will be to protect life. Refer to the site specific Emergency Response Plans and, where required, the FRP, OME Manual, H2S Contingency Plan, HAZWOPPER Plan or SPCC Plan for specific procedures in site emergencies.
B. Internal Alert Procedures
The following flowchart explains the internal notification procedures required in the event of an emergency:
Discovery of emergency by operator, contractor, etc. Operator, Contractor, Etc. Notify Site Supervisor or Drilling Contractor in charge of location.
Receive pertinent information regarding emergency such as: material released, quantity of released material, location, date and time of release, actions required to mitigate emergency, weather conditions, Site Supervisor or Drilling number of injuries/fatalities, whether evacuations are Contractor in Charge of necessary, source or cause of emergency, and a Location description of the medium (land, water, or air) impacted. Mobilize onsite response personnel. Notify Operations Superintendent or Senior Safety Officer.
Receive all pertinent information, mobilize offsite
response personnel, and conduct verbal notification Operations (as necessary) to all appropriate local, state, and Superintendent/Sr. Safety federal agencies. Notify Land and Insurance Officer Groups and any other necessary groups/individuals within Company
Senior Safety Officer Correspond with Senior Management
Note: If any level is unavailable, proceed to next level of contact.
The list of contacts is maintained in the site specific Emergency Response Plan, FRP, OME Manual, H2S Contingency Plan, HAZWOPPER Plan or SPCC Plan located at the site. All information concerning the site emergency should be relayed as accurately and concisely as possible. However, internal notifications should be conducted as soon as possible and the lack of information pertaining to the emergency should NOT prohibit internal notifications from being performed.
12-2017 Page 12 of 114
C. External Alert Procedures
Appropriate regulatory agencies shall be notified of any emergency in accordance with federal, state, and local reporting requirements.
If a reportable spill or release is observed (under the Clean Water Act), notify the National Response Center (1-800-424-8802).
Individual state and local response agencies will also be contacted regarding a reportable spill or release. The phone numbers for the specific agencies are listed in the applicable FRP, OME Manual, H2S Contingency Plan, HAZWOPPER Plan or SPCC Plan designated for the Company property involved with the spill or release.
NOTE: A reportable quantity discharge or spill of oil, under the Clean Water Act, is defined as any amount of any substance that will create a sheen, discoloration, or emulsification on or below the surface of the water. Reportable quantities of oil not reaching water will vary based on state and local laws and regulations.
NOTE: Local, state, and federal agencies may also require notification upon the release of discharge of gases, such as H2S, natural gas or carbon dioxide (CO2), in sufficient quantities which could create a fire, explosion, health hazard, or exceed reportable quantities cited in local, state, and federal laws and regulations.
External spill or release notifications will include:
1. exact address and phone number of the facility;
2. the spill/release date and time;
3. the type of material spilled or released;
4. estimates of the total quantity spilled or released;
5. estimates of the quantity spilled into navigable waters;
6. the source and cause of the spill or release;
7. a description of the affected medium (air, water and/or soil);
8. any damages or injuries caused by the spill or release;
9. actions being used to stop, remove and mitigate the effects of the spill or release;
10. whether an evacuation may be needed;
11. names of individuals and/or organizations who have also been contacted; and 12-2017 Page 13 of 114
12. Company contact person and phone number.
Emergency numbers for emergency transportation to a medical facility are included in the site specific Emergency Response Plan, FRP, OME Manual, H2S Contingency Plan, HAZWOPPER Plan and SPCC Plans.
D. Chain of Command and Communications
Where appropriate, the Incident Command System (ICS) established by the National Incident Management System (NIMS) may be implemented for site emergencies, spills, and releases as outlined in the various emergency response programs.
V. MEDICAL EMERGENCIES
A. In the event of a medical emergency, the following procedures will be followed:
1. Immediately seek medical attention. While awaiting emergency medical treatment, employees may provide first aid.
2. Return operation to a safe condition, if possible, or shutdown the process.
3. Notify supervisor.
4. Secure the facility and control access to the area.
5. Do not discuss the incident with anyone other than the supervisor/manager, Senior Safety Officer or his designee, Human Resources or Company legal counsel.
6. Handle contractors’ personnel injuries in the same manner, except notify contractor's supervisors or law enforcement personnel within the jurisdiction as soon as possible.
B. Injuries or accidents will be reported and documented in accordance with Section 5, Accident/Injury Investigation and Reporting.
12-2017 Page 14 of 114
5. ACCIDENT / INJURY INVESTIGATION AND REPORTING
I. PURPOSE/SCOPE
This section provides the internal procedures and requirements for reporting and investigating work-related accidents, fatalities, injuries, or illnesses in addition to the OSHA requirements for recording and reporting work-related fatalities, injuries, and illnesses. Accident/injury reporting and investigation assists the Company in identifying the underlying causes of accidents and injuries so that the Company may learn from past experiences and prevent similar events from occurring in the future. The cooperation of employees is essential to an effective incident investigation.
II. GENERAL POLICY
A. Employees shall immediately report all work-related accidents involving injuries, fatalities and/or damage to Company equipment, property, or material to their supervisor.
B. Employees shall report any work-related “near miss” to their supervisor as soon as possible. A “near miss” is an incident caused by a faulty process, human error or mechanical failure that could have resulted in an injury, fatality, property damage, a release, or a fire/explosion.
C. Any work-related fatality or accident requiring the hospitalization of 3 or more employees must be orally reported to OSHA within 8 hours of learning of the incident. This report must be submitted even if the fatality or hospitalization occurs up to 30 days after the incident. The report must contain:
1. name of facility;
2. location of incident;
3. time of incident;
4. number of fatalities or hospitalized employees;
5. names of any injured employees;
6. Company contact person and his or her phone number; and
7. brief description of incident.
12-2017 Page 15 of 114
D. Records of work-related accidents, injuries, fatalities, and illnesses and investigations relating to such incidents will be maintained by the Operations Department or their designee for review and evaluation by appropriate Company employees. Such records will be retained for a minimum of 5 years following the calendar year that these records cover.
E. The Company’s workers compensation carrier will be notified to report any work-related injury or illness claims in accordance with their policies.
F. The Company may require any employee who causes or contributes to an accident to submit to a post-accident drug or alcohol test.
G. Applicable federal or state laws and regulations governing accident/injury reporting and investigation will be followed.
III. ACCIDENT / INJURY REPORTING
A. Incident Report
1. All work-related accidents involving injuries, illnesses, and fatalities and/or damage to Company equipment, property, or material shall be recorded on the Perdure TRP Initial Incident Report.
2. The Incident Report shall be completed within 24 hours of any such incident and sent to the Corporate Office.
3. Any first aid or medical treatment provided for work-related injuries or illnesses shall be described on the Incident Report form.
4. The site supervisor must review the Incident Report and acknowledge the findings in the Incident Report by signing it.
5. Where required, information on the Incident Report will be transferred to the appropriate OSHA form described below.
6. A copy of the Incident Report form is located on Appendix 2: Forms.
B. Lost Work Day Occurrence
1. All accidents involving lost work days will be reported as quickly as possible to the Worker's Compensation insurance carrier by the Operations Department or their designee.
2. This information will be entered on the appropriate OSHA forms and an investigation will be initiated by the site supervisor.
12-2017 Page 16 of 114
C. Return to Work
1. If time was lost due to an occupational injury, the employee will present a physician's release when they return to work. The employee will obtain this release during their last visit to the doctor before returning to work.
2. When an employee is returning to work for an off-the-job injury, they will be required to have a medical release from their family physician. There may be cases where a release will be required from a doctor selected by the Company, such as back injuries and hernias.
D. OSHA Records for Injuries and Illnesses
1. Each work-related injury or illness that is a new case and results in one of the following must be recorded on the appropriate OSHA form:
a. death;
b. days away from work;
c. restricted work or transfer to another job;
d. medical treatment beyond first aid; and/or
e. loss of consciousness
2. A significant work-related injury or illness diagnosed by a physician or other licensed healthcare professional must also be recorded on the appropriate OSHA form, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.
3. Needlestick and sharps injuries, tuberculosis cases, hearing loss cases, medical removal cases, and musculoskeletal disorders cases must also be recorded on the appropriate OSHA form as required by 29 CFR 1904.8 through 29 CFR 1904.12.
4. The Operations Department will review any work-related injury or illness and determine if it is an OSHA recordable and complete the appropriate OSHA forms. The following OSHA forms, or their equivalent, will be completed for recordable injuries and illnesses:
a. The OSHA 300 Log provides a brief description of each recordable injury or illness.
b. The OSHA 300-A form summarizes the information on the OSHA 300 Log at the end of the year.
12-2017 Page 17 of 114
c. The OSHA 301 Incident Report is used for each recordable injury or illness entered on the OSHA 300 Log.
5. In privacy concern cases, an employee’s name will not be entered on the OSHA 300 Log. A separate, confidential list of the case numbers and employee names will be maintained.
6. At the end of each calendar year, the Operations Department will review the OSHA 300 Log to verify that the entries are complete and accurate and create an annual summary of the injuries and illnesses recorded on the OSHA 300 Log. The annual summary will be posted in a conspicuous place from February 1 to April 30 of each year for the previous 12-month reporting period.
7. The OSHA 300 Log, the privacy case list (if one exists), the annual summary, and the OSHA 301 Incident Report will be retained for 5 years from the end of the calendar year that these records cover. Updates or changes to these records will follow established OSHA procedures.
8. The number of man-hours worked each month must be calculated and retained for use in figuring accident rates and for completing any supplemental survey reports requested by OSHA or the Bureau of Labor Statistics (BLS).
E. Near Miss Report
1. When a near miss occurs, the employee observing the near miss will complete the Near Miss Investigation Report form located in Appendix 2: Forms.
2. The site supervisor must review the Near Miss Report and acknowledge the findings in the Near Miss Report by signing it.
3. The completed Near Miss Report will be sent to the Operations Department or maintained at the work location.
F. Automobile Accident Report
1. Any accidents involving a Company vehicle shall be reported to the Company Senior Safety Officer as soon as possible. The Senior Safety Officer will be responsible for contacting other applicable parties.
2. The Perdure TRP Driver’s Vehicle Accident Report will be completed in its entirety and forwarded to the Operations Department or their designee within 24 hours after the accident.
3. A copy of the Perdure TRP Driver’s Vehicle Accident Report form is located in Appendix 2: Forms.
12-2017 Page 18 of 114
IV. ACCIDENT / INJURY INVESTIGATION
A. The Company shall investigate each incident which resulted in a catastrophic release of chemical or hydrocarbon or any OSHA recordable accident. A near miss may be investigated at the Company’s discretion.
B. The investigation shall be initiated as promptly as possible, but not later than 48 hours following the incident. While the investigation team is being formed, the facts surrounding the incident or accident should be collected by the site supervisor.
C. Investigation Team
1. An investigation team will be assembled to investigate incidents which resulted in a catastrophic release of chemical or hydrocarbon, or accidents involving an injury or fatality or a near miss.
2. The Senior Safety Officer will be responsible for forming the team.
3. The structure of the investigation team should reflect the scope and complexity of the incident. The team shall consist of at least one person knowledgeable in the process involved and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident.
4. Where appropriate, the investigation team may include a contractor’s representative, if the incident involved the contractor’s operations, equipment or personnel.
12-2017 Page 19 of 114
D. Investigation Report
1. At the conclusion of the investigation, the investigation team shall prepare an investigation report.
2. The report shall include at least the following information:
a. date of accident/incident;
b. date investigation began;
c. description of the incident;
d. factors that contributed to the incident; and
e. recommendations resulting from the investigation.
3. A copy of the investigation report will be retained for a minimum of 5 years.
E. The findings and recommendations from the investigation team will be promptly addressed and resolved. The investigation team will provide a list of recommended corrective actions that will be assigned to various employees and/or departments.
F. The findings and recommendations that are pertinent to the health and safety of the employees will be communicated to all affected or potentially affected employees through one or more of the following:
1. regularly scheduled safety meetings;
2. tailgate safety meeting;
3. ad hoc meeting; and
4. Safety Alert.
G. If the accident or incident involves contractor’s personnel, the findings and recommendations shall be reviewed with the contractor.
12-2017 Page 20 of 114
6. FIRST AID
I. GENERAL POLICY
A. The Company will ensure the availability of medical personnel for advice and consultation on health matters.
B. In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be made readily available.
C. Where the eyes or body of any person may be exposed to injurious corrosive materials, a suitable method for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.
D. All injuries will be reported in accordance with guidelines in Section 5, Accident/Injury Investigation and Reporting.
II. FIRST AID KITS
First aid kits should contain the contents described in the American National Standard Institute (ANSI) Z308.1-1998 “Minimum Requirements for Workplace First-Aid Kits.” The Company should determine the need for additional first aid kits at the site, additional types of first aid equipment and supplies and additional quantities and types of supplies and equipment in the first aid kits.
III. AUTOMATED EXTERNAL DEFIBRILLATOR (AED)
AED’s may be provided at certain Company locations. The Company will offer training to employees on the use of AED’s. Employees should be familiar with the location of the AED at their site.
12-2017 Page 21 of 114
7. PERSONAL PROTECTIVE EQUIPMENT (PPE)
I. PURPOSE/SCOPE
Personal protective equipment (PPE) is vital to safety at any work location. PPE shall be used where needed by all employees of the Company to comply with 29 CFR 1910.132-138.
II. GENERAL POLICY
Refer to the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Personal Protective Equipment (PPE) Program for specific requirements related to PPE. A copy of the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Personal Protective Equipment (PPE) Program is located in Appendix 1: Programs.
A. All work areas are to be evaluated to determine if hazards are present or likely to be present through a workplace hazard assessment. PPE will be selected and required based on the hazards identified in the hazard assessment. The Company shall verify that the required workplace hazards assessment has been performed through a written certification that identifies:
1. the workplace evaluated;
2. the person certifying that the evaluation has been performed;
3. the date(s) of the hazard assessment; and
4. the document as a certification of hazard assessment.
B. At minimum, hard hats, safety glasses, protective footwear and flame resistant clothing are mandatory for employees regularly stationed in the field.
C. PPE is used to protect breathing, hearing, eyesight and all body limbs from injury. The equipment will be properly cleaned and inspected after use then stored in clearly marked and properly designated areas. If there is any doubt of the PPE needed either to wear, or for use in an operation, employees should contact their supervisors. Contractors will contact their representative concerning questions on PPE.
D. Visitors on guided tours shall be required to wear the necessary PPE as designated by the Company representative conducting the tour. The tour leader is responsible for assigning PPE that provides adequate protection to any potential hazards that may be encountered on the tour. Hard hats and safety glasses are mandatory on all tours. “Visitors” shall mean: 12-2017 Page 22 of 114
1. all employees, whether or not regularly stationed in the field, who are unfamiliar with the field location; and
2. all non-employees invited, with permission, to enter the field location for their own benefit and/or for the benefit of the Company.
E. The Company will provide training to employees on PPE. Documentation of training will be maintained by the Operations Department or at the work location.
IV. RESPIRATORY PROTECTION
Refer to the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Respiratory Protection Program for specific requirements related to respiratory protection. A copy of the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Respiratory Protection Program is located in Appendix 1: Programs.
A. If employees are involved in situations which require the use of a respirator, the Company will provide the necessary respiratory protective equipment and training for the protection, health and wellbeing of the employee. Where practical, respiratory protective equipment will be assigned to individual employees for their exclusive use.
B. Contractors who use respiratory protection while performing work on Company sites will implement a written program that meets the requirements of the OSHA respiratory standard 29 CFR 1910.134 and the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Respiratory Protection Program.
C. Respiratory protection equipment will be worn properly at all times when an employee is in a contaminated atmosphere which may result in overexposure. If there is any doubt as to the respiratory protection equipment required for a particular task, employees shall consult with their supervisor.
V. HEARING PROTECTION
Refer to the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Hearing Conservation Program for specific requirements related to hearing protection. A copy of the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Hearing Conservation Program is located in Appendix 1: Programs.
A. Hearing protection will be available when the sound levels exceed those shown in the Table 7-1 when measured on the A scale of a standard sound level meter at slow response. The Company will, when practical, 12-2017 Page 23 of 114
make every effort to reduce sound levels within the levels shown in Table 7-1 with administrative and engineering controls. If such controls fail to reduce the sound levels within the levels shown in Table 7-1, hearing protection shall be provided and used to reduce the sound levels within the levels provided in Table 7-1.
TABLE 7-1 PERMISSIBLE NOISE EXPOSURES* (Without Use of Ear Plugs or Muffs) (29 CFR 1910.95)
Duration Per Day in Hours Sound Level, dB 8…………………………………………………...……...90
6…………………………………………………...……...92
4…………………………………………………...……...95
3…………………………………………………...……...97
2………………………..………………………...……...100
1-1/2……………………………………………...……...102
1…...………………………………………...……...…...105
1/2……………………………………………...…...…...110
1/4 or Less. ……………………………………………...115
COMMON NOISE REFERENCE POINTS (in dB)
Residential/Office Areas…………………………………..45
Loud Speech……………………………………………….75
Road Traffic……………………………………….……80-85
Workshop Machinery/Generators……………….…80–180
Threshold of Comfort……………………………………125
Threshold of Pain………………………………………..130
*When the daily noise exposure is composed of 2 or more periods of 12-2017 Page 24 of 114
noise exposure of different levels, their combined effect should be considered, rather than the individual effect of each.
B. Warning signs will be posted in areas where sounds levels exceed those shown in the preceding Table 7-1. Hearing protection shall be worn in areas where such warning signs are posted. Hearing protection shall also be worn in unmarked areas where noise levels temporarily exceed those in the preceding Table 7-1, such as where high pressure gases are released or where large motors or compressor units are running.
C. Contractors are expected to provide hearing protection for their personnel.
IV. EYE AND FACE PROTECTION
In accordance with 29 CFR 1910.133 (b), all eye protection shall comply with ANSI Z87.1.
A. Suitable eye and face protection shall be worn where there is a potential for eye injury from machines, flying objects and particles, glare, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, injurious radiation or a combination of these.
B. Suitable eye and face protection shall be worn when handling acids, chemicals or other hazardous liquids that may blow or splash into the eyes or face.
C. Eye protection will be furnished by the Company for all employees and visitors. Employees may request prescription safety glasses where applicable and approved by their supervisor. Contractors are responsible for safety glasses for their personnel. Side shields are required.
D. Minimum requirements for eye protectors:
1. provide adequate protection against the particular hazards for which they are designed;
2. be reasonably comfortable when worn under the designated conditions;
3. fit snugly without interfering with the movements or vision of the wearer;
4. be durable, easily cleaned and capable of being disinfected; and
5. be kept clean and in good repair. E. Contact lenses:
1. When contact lenses are worn, goggles or special safety glasses with side shields will be worn for additional protection where eye 12-2017 Page 25 of 114
protection is required.
2. Contact lenses will not be worn in field operations where there is a risk of chemical spray.
3. Wearers of contact lenses will inform their supervisors and co- workers that they wear the lenses so that proper emergency treatment can be given if necessary.
F. Impact-type goggles will be worn when engaging in any activity that involves hazards to the unprotected eye from chipped or flying particles including but not limited to chipping, scraping, buffing, and grinding.
G. Dust-proof goggles will be worn when dust hazards exist and when using any type of pneumatic tool.
H. Splash-proof goggles will be worn when handling hazardous chemical liquids, powders or vapors. Employees in the immediate vicinity of such chemicals, powders, or vapors shall also wear splash-proof goggles.
I. An approved cover-glass, impact-type safety goggle for use over corrective glasses may be worn by employees who are only occasionally exposed to eye hazards.
J. A person near other persons who are doing work that requires the use of safety goggles will also wear such goggles.
K. Welding will not be directly watched without proper eye protection.
L. Employees shall wear eye protection with filter lenses that have a shade number appropriate for the work being performed for protection from injurious light radiation as set forth in the following Table 7-2:
TABLE 7-2 Filter Lenses for Protection Against Radiant Energy (29 CFR 1910.133) Plate Plate Minimum Operations Thickness – Thickness - Protective inches mm Shade Gas Welding: Light Under 1/8 Under 3.2 4 Medium 1/8 to 1/2 3.2 to 12.7 5 Heavy Over 1/2 Over 12.7 6
Oxygen Cutting: Light Under 1 Under 25 3 Medium 1-6 25 to 150 4 Heavy Over 6 Over 150 5
12-2017 Page 26 of 114
Minimum Electrode OpOperationserations ArcArc CurrentCurrent Protective Size 1/32 in. Shade Less thanthan 3 Less than 60 7 ShieldedShielded Metal Arc 3-5 60-160 8 Welding 5-8 160-250 10 MoreMore than 8 225050-555500 11 Less than 60 7 Gas Metal Welding 6060-160 10 and FFluxlux Cored Arc 160-250 10 Welding 250-500 10 Less than 50 8 Gas TungstenTungsten Arc 50-150 8 Welding 150-500500 10 Air Carbon (Light) LessLess than 500 1100 10 Arc Cutting (Heavy) 500-1000 11 Less than 20 6 PlasmPlasmaa Arc 20-100 8
Welding 100-404000 10 400-800 11 (Light) Less than 300 8 Plasma Arc CuttingCutting (Medium) 300-400 9 (Heavy) 400400-800 10 Torch Brazing 3 TorchTorch Soldering 2 Carbon Arc CuttingCutting 14
V. PROTECTIVE FOOTWEAR
A. Protective footwear shall be used when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, and where feet are exposed to electrical hazards. Protective footwear shall comply with ANSI Z41.1.
B. Safety toe shoes/boots meeting ANSI Z41.1 specification shall be worn at all field locations and other designated areas which require the use of such footwear. Other types of special protective footwear, such as rubber boots, foot protectors and metatarsal guards shall be worn when required.
C. The Company will provide a single pair of safety toe shoes/boots per year for each employee required to wear them.
VI. HAND PROTECTION
A. Appropriate hand protection shall be worn when hands are exposed to harmful chemicals or extreme temperatures or when hands are at risk for severe cuts or lacerations, severe abrasions, punctures, chemical burns, and thermal burns.
B. Wearing gloves prevents many minor injuries resulting from rough materials or irritating substances (solvents, acids, etc.). 12-2017 Page 27 of 114
C. Hand protection shall be selected based on the performance of the hand protection relative to the task to be performed, conditions, present, duration of use, and the hazards identified.
1. Gloves made of non-porous materials which are capable of preventing substance contact to the skin through absorption should be used when handling hazardous and irritating substances.
2. Leather or leather-palm gloves should be worn when wire rope is being handled.
3. Cloth gloves afford adequate protection when pipe is handled and for general lease operation.
4. Rubber gloves designed for electrical work are required where operations involve high voltage/high energy electrical systems.
5. Insulated or heat-resistant gloves will be worn when regular work gloves cannot adequately protect against burns.
D. Gloves are necessary to protect the hands; however, extreme caution should be exercised if it is necessary to wear these gloves around moving machinery.
VII. HEAD PROTECTION
A. Employees, contractors, and visitors shall wear hard hats at all times, except in vehicles, control rooms, or offices.
B. Hard hats shall also be worn at any other location when there is a potential for injury to the head from falling objects or overhead obstructions.
C. Hard hats designed to reduce electrical shock hazards shall be worn near exposed electrical conductors which could contact the head.
D. Contractors are required to provide hard hats for their personnel.
E. All hard hats shall comply with the ANSI Z89.1 standard.
F. Hard hats may not be required during welding operations if they interfere with wearing a welding shield. In such instances, protection from overhead hazards shall be considered.
G. Hair long enough to constitute a hazard while a person is working near moving machinery or rotating tools and equipment will be secured by a net or tied back. Hair styles that make it impossible for a person to properly wear a hard hat are not permitted. 12-2017 Page 28 of 114
H. Beards that constitute a hazard while a person is near moving machinery or rotating tools are not permitted.
VIII. CLOTHING
A. Clothing suited to the work, the weather and the environment in which the employee works will be worn, such as:
1. Clothing made of cotton material is best for oil field work unless flame resistant clothing (FRC) is used.
2. Clothing resistant to static electricity should be used where flammable vapors are present.
3. Flame resistant clothing is required when working near any wellsite of facility where hydrocarbons are present.
B. Generally speaking, clothing of a material with good resistance to abrasion and not easily ignited by heat or flame should be worn. Oily and greasy clothing create a fire hazard and may cause skin irritation.
C. Clothing should fit well, and pants cuffs should be sewn down. Loose cuffs or baggy clothing should be avoided.
D. Jewelry such as rings, watchbands, or neck chains, in certain work areas, (e.g., around moving machinery, rotating tools, etc.) is prohibited.
E. A person working around moving machinery will not wear neckties or neck chains, gauntlet gloves or gloves that fasten around the wrists or baggy, loose or ragged clothing.
F. Never tie or otherwise attach a rag or handkerchief to your person in such a manner that it cannot be removed with one quick, easy pull.
G. If clothing becomes saturated with oil, gasoline or chemicals, the employee should immediately change clothes to prevent skin irritation. Refer to product Materials Safety Data Sheet for proper decontamination procedures.
H. Flame resistant clothing will be provided and mandated by the Company for employees regularly stationed in the field.
12-2017 Page 29 of 114
IX. FALL PROTECTION
Fall protection will be required when working 6 feet or more above ground level unless otherwise required. All components of the fall protection system shall meet the latest revision of ANSI A10.32.
A. When using a tie-off system, the system must be tied-off properly to anchor points that are capable of supporting a static load of 5,000 lbs per person attached. These anchor points should be independent of any anchorage being used to support or suspend the temporary platform or structure. D. A full body harness is required when using a tie-off system.
E. Personal fall protection systems and components which have been subjected to impact from an employee's fall will be immediately taken out of service and destroyed.
X. PERSONAL FLOTATION DEVICES (IF BECOMES APPLICABLE)
A. In the event an employee is traveling on water, personal flotation devices (PFD’s) will be worn:
1. during over-water transfers between vessels and structures;
2. on platforms, decks, or barges when guard rails are not present and in other similar situations when there is exposure to falling into the water; and
3. operating or riding in any open water craft.
B. The PFD must be U.S. Coast Guard approved and properly buckled and adjusted.
C. Type 4 flotation devices (throwable cushions or ring buoys) cannot be used as a primary means of flotation.
12-2017 Page 30 of 114
8. HAZARD COMMUNICATION (HAZCOM)
I. PURPOSE/SCOPE
The purpose of this section is to establish policies and procedures for receipt, safe use, safe handling, and safe storage of chemicals in the workplace. The Company has established the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Hazard Communication (HAZCOM) Program to evaluate the hazards of all chemicals used by the Company and provide information concerning their hazards to employees.
II. GENERAL POLICY
All communications related to the hazards of chemicals in the workplace will comply with 29 CFR 1910.1200. Refer to the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Hazard Communication (HAZCOM) Program for specific requirements related to hazard communication. A copy of the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Hazard Communication (HAZCOM) Program is located in Appendix 1: Programs.
The Company shall:
A. obtain information as to physical and health hazards associated with products and/or materials used in the workplace prior to the purchase, use or disposal of such products. The Company relies on the accuracy of the hazard determination made by the products producer. This information is received via Material Safety Data Sheets (MSDS) and the product label on the containers;
B. confirm that labels on incoming containers of hazardous chemicals are not removed or defaced and that the identity of the product or material, the hazardous components, the principle hazards and the appropriate warnings and/or precautions necessary for its use are all included and legible;
C. provide employees who use or otherwise come in contact with the product or material access to information regarding the hazards associated with the product and/or material;
D. keep medical and exposure records, for any employee coming into contact with a toxic substance, for the duration of employment plus 30 years. An employee or designated representative shall have access to examine or copy his or her personal medical and exposure records; and
12-2017 Page 31 of 114
E. provide training to employees on HAZCOM. Documentation of training will be maintained by the Operations Department or at the work location. Refer to the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Hazard Communication (HAZCOM) Program for hazardous communication training requirements.
III. CONTRACTORS
A. Site supervisors are responsible for:
1. informing contractors of hazards their personnel may be exposed to while performing their work. This information will be communicated by means of a Safe Work Permit.
2. making the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Hazard Communication (HAZCOM) Program available to contractors.
B. All contractors will have access to the list of the hazardous chemicals and appropriate MSDS’s which they will be, either, using or exposed to while performing their jobs.
12-2017 Page 32 of 114
9. LOCKOUT/TAGOUT (LOTO)
I. PURPOSE/SCOPE
The LOTO procedures apply to the servicing and maintenance of machines and equipment in which the unexpected energization or start-up of the machines or equipment or release of stored energy could cause injury. The LOTO procedures do not apply to: (i) oil and gas well drilling and wellhead servicing and hot tap operations; (ii) handheld power tools where a cord can be unplugged to cut power to the equipment when the plug is within the control of the operator; or (iii) routine operations, such as, sight glass removal/installation, choke changes, removing/replacement of instruments, and pigging operations.
The specific objectives of this section are as follows:
A. to establish a safe and positive means of shutting down machinery, equipment and systems;
B. to prohibit unauthorized employees or contractors’ personnel, or remote control systems, from starting machinery or equipment while it is being serviced;
C. to provide a secondary control system (tagout) when it is impossible to positively lockout the machinery or equipment;
D. to establish responsibility for implementing and controlling LOTO procedures; and
C. to verify that only approved locks, standardized tags and fastening devices provided by the Company will be utilized in the LOTO procedures.
II. DEFINITIONS
Term Description To put a padlock on an energy isolating device such as a disconnect switch or valve, after the machine has been shutdown, Lockout to prevent the equipment from being operated until the lockout device has been removed.
To put special tags on equipment energy isolating devices to warn other employees that the equipment must not be operated until the Tagout tags are removed by Authorized Employees.
12-2017 Page 33 of 114
An employee who either: (1) locks out or tags out machinery in order to perform service or maintenance; or (2) implements a LOTO system procedure on machines or equipment, such as Authorized performing energy source isolation, implementing LOTO, releasing Employee stored energy, verifying energy isolation, releasing LOTO, or testing or positioning machinery or equipment.
An employee whose job requires him or her to operate or use a machine or equipment on which service or maintenance is being Affected performed or whose job requires him or her to work in an area in Employee which such servicing or maintenance is being performed.
Refer to the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Lockout/Tagout (LOTO) Program for additional definitions.
III. GENERAL POLICY
Refer to the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Lockout/Tagout (LOTO) Program for specific requirements related to LOTO. A copy of the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Lockout/Tagout (LOTO) Program is located in Appendix 1: Programs.
A. All machines and equipment undergoing service or maintenance shall be locked out or tagged out to protect against injury due to the unexpected energization or start up of a machines or equipment or the release of stored energy.
B. All new equipment installations, replacement equipment or equipment undergoing major restoration shall include lockout capability.
C. Existing equipment which cannot be secured by lockout shall be secured by utilizing the tagout system.
D. Locks and tags meeting the requirements set forth in the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Lockout/Tagout (LOTO) Program shall be provided to employees.
E. The LOTO procedures shall be inspected at least annually. The inspection shall be performed by the Operations Department provided the individual doing the inspection is not the person utilizing the energy control procedure under inspection. The inspections shall be performed and documented in accordance with the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Lockout/Tagout (LOTO) Program.
F. The Company will provide training to employees on LOTO. Documentation of training will be maintained by the Operations Department or at the work location.
12-2017 Page 34 of 114
IV. AREAS OF RESPONSIBILITY
A. Authorized Employees are responsible for following the LOTO procedures established by this section and the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Lockout/Tagout (LOTO) Program.
B. Affected Employees are responsible for ensuring that they do not attempt to restart or re-energize machines or equipment which have been locked or tagged out by an Authorized Employee.
C. Supervisors are responsible for enforcing the requirements of this section and the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Lockout/Tagout (LOTO) Program and for ensuring compliance with the procedures in their department.
D. The Operations Department is responsible for monitoring the compliance with the procedures of this section and the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Lockout/Tagout (LOTO) Program and will conduct the annual inspection of certification of the Authorized Employees.
V. PROCEDURES
A. Locking Out and/or Tagging Out
1. The Authorized Employee shall notify Affected Employees before applying the LOTO devices
2. To prepare for shutdown, the Authorized Employees shall perform a survey and identify all isolating devices. Authorized Employees must be familiar with the different energy sources and the proper sequence of shutting off or disconnecting energy means. The common types of energy sources are: electrical, mechanical, pneumatic, hydraulic, pressure and kinetic. More than one energy source can be utilized on some equipment, and the proper procedure set forth in the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Lockout/Tagout (LOTO) Program must be followed in order to identify energy sources and LOTO accordingly. A sample copy of a Lockout/Tagout Procedure Form is located in Appendix 2: Forms.
3. The Authorized Employee shall shut down the machine or equipment by using the procedures established for the machine or equipment.
4. The Authorized Employee shall physically locate all energy isolating devices that are necessary to control energy to the machine or equipment and operate such devices in a manner which isolates the energy source from the machine or equipment.
12-2017 Page 35 of 114
5. The Authorized Employee shall apply a lockout or tagout device to each energy isolating device
6. All potentially 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 servicing or maintenance is completed or until the possibility of such accumulation no longer exists.
7. Prior to starting work on machines or equipment that have been locked or tagged out, the Authorized Employee shall verify that isolation and de-energization of the machine or equipment have been accomplished. “Verification” means trying to start, turn on or activate the machine or equipment.
B. Release from Lockout/Tagout
1. The Authorized Employee shall inspect the work area to ensure that nonessential items have been removed and to ensure that the machine and equipment components are operationally intact. Any guards on equipment shall be replaced and fully functional.
2. The Authorized Employee shall verify that all Affected Employees have been removed from the area and are at a safe distance from the machine or equipment.
3. The Authorized Employee shall remove the LOTO devices. Each Authorized Employee shall only remove his or her lock or tag. When the Authorized Employee who applied the device it not available to remove it, the following procedure shall be followed:
a. Notify the supervisor and inform him or her of the situation.
b. Verify that the Authorized Employee who applied the device is not in the facility or field.
c. Make all reasonable efforts to advise the Authorized Employee that his or her LOTO device has been removed. (This can be done when he or she returns to the facility or field.)
d. Ensure that the Authorized Employee has this knowledge before he or she resumes work at the facility.
4. The Authorized Employee shall notify Affected Employees that the LOTO devices have been removed before the machine is started.
C. Group LOTO
Refer to the Geo Fossil Fuels, Tabula Rasa Energy, Perdure 12-2017 Page 36 of 114
Petroleum Lockout/Tagout (LOTO) Program for Group LOTO Procedures.
D. Shift or Personnel Changes
Specific procedures shall be utilized during shift or personnel changes to ensure the continuity of LOTO protection, including provision for the orderly transfer of LOTO device protection between outgoing and incoming employees and/or contractor’s personnel, to minimize exposure to hazards from the unexpected energization or start-up of the machine or equipment, or the release of stored energy.
VII. CONTRACTORS
A. Whenever a contractor is to be engaged in activities covered by the scope and application of this policy and procedures, the Company and the contractor shall inform each other of their respective LOTO procedures.
B. The site supervisor shall confirm that Affected Employees understand and comply with the contractor’s LOTO procedures.
12-2017 Page 37 of 114
10. CONFINED SPACE
I. PURPOSE/SCOPE
The purpose of this section is to protect employees from the hazards associated with entering a Permit-Required Confined Space (Permit Space). Employees are prohibited from conducting any confined space entry. Confined space entry is to be performed exclusively by qualified, trained contractors who are engaged through the MSA process. The following is guidance for the management of such contractors:
II. DEFINITIONS
Term Description Any piece of equipment, tank, processing tower, sump, underground utility vault, trenches, excavations, ducts, flues, valve boxes, cellars, pits, equipment housing, etc. which is Confined large enough or so configured that anyone can bodily enter and Space perform the assigned work; has a limited or restricted means for entry or exit; and is not designed for continuous occupancy.
Non-Permit A Confined Space that does not contain, or have the potential to Confined contain, any hazards capable of causing death or serious Space physical harm. A Confined Space that is potentially hazardous due to one or more of the following characteristics:
1. Contains or has the potential to contain a hazardous atmosphere;
2. Contains a material that has the potential for engulfing the entrant;
3. Has an internal configuration such that an entrant could be Permit trapped or asphyxiated by inwardly-converging walls or by Space a floor that slopes downward and tapers to a smaller cross-section; and
4. Contains any other recognized serious safety or health hazard, including but not limited to the following: fall hazards, unguarded machinery, extreme heat or cold, steam pipes or chemical lines, hazardous noise levels, electrical hazards, presence of asbestos, or potentially hazardous levels of dust.
12-2017 Page 38 of 114
The action by which a person passes through an opening into a Permit Space and is considered to have occurred as soon as Entry any part of the Authorized Entrant’s body breaks the plane of an opening into the space.
The site supervisor or the designated representative, such as the foreman or crew chief, responsible for determining if acceptable entry conditions are present at a Permit Space Entry where entry is planned; for authorizing entry and overseeing Supervisor entry operations; and for terminating entry as required by the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Confined Space Entry Program.
An employee who is approved or assigned by the site supervisor in charge of the entry to enter the Permit Space. Authorized Refer to the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Entrant Petroleum Confined Space Entry Program for training requirements and specific duties of Authorized Entrants.
An employee designated by the site supervisor in charge of entry to remain outside the Permit Space and to be in constant Attendant communication with the Authorized Entrant(s) working inside the Permit Space.
Refer to the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Confined Space Entry Program for additional definitions.
III. GENERAL POLICY
Refer to the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Confined Space Entry Program for specific requirements related to Confined Space entry. A copy of the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Confined Space Entry Program is located in Appendix 1: Programs.
A. All Confined Space operations will comply with 29 CFR 1910.146.
B. Warning signs stating “DANGER – PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER” or using other similar language shall be posted by the entrance to Permit Spaces to inform employees of the existence and location of and the danger posed by Permit Spaces.
C. Employees are prohibited from conducting any confined space entry. Confined space entry is to be performed exclusively by qualified, trained contractors who are engaged through the MSA process.
12-2017 Page 39 of 114
D. A Confined Space Entry Permit is required before an Authorized Entrant may enter a Permit Space. A copy of the Confined Space Entry Permit form is located in Appendix 2: Forms. The Confined Space Entry Permit is an authorization and approval, in writing, that specifies the location and type of work to be done, certifies that all existing hazards have been evaluated by a qualified person and necessary protective measures have been taken to ensure the safety of each worker.
E. Only employees trained in the hazards of Confined Space entry will be authorized to work in Confined Spaces.
IV. AREAS OF RESPONSIBILITY
A. Entry Supervisors shall designate Authorized Entrants and Attendants.
B. Employees are prohibited from conducting any confined space entry. Confined space entry is to be performed exclusively by qualified, trained contractors who are engaged through the MSA process.
C. Contractors shall be responsible for maintaining records for their personnel and ensuring that Company policy is followed by their personnel.
12-2017 Page 40 of 114
11. HOT WORK
I. PURPOSE/SCOPE
The purpose of this section is to establish proper safety precautions for the performance of work which requires an open flame or results in a spark in areas where catastrophic releases of toxic, reactive, flammable, or explosive materials could result in an uncontrolled emission, fire or explosion hazard. Such work includes electric or gas welding, cutting, brazing or similar flame or spark- producing operations (referred to herein as “Hot Work”).
II. GENERAL POLICY
A Hot Work Permit will be required for any work which requires an open flame or results in a spark in areas where catastrophic releases of toxic, reactive, flammable, or explosive materials could result in an uncontrolled emission, fire or explosive hazard. Such work includes electric or gas welding, cutting, brazing or similar flame or spark-producing operations. The Company may designate specific areas that may be exempt from this policy (e.g., welding shops). A copy of the Hot Work Permit form is located in Appendix 2: Forms.
III. PERMIT PROCEDURES
Employees and/or contractors’ personnel shall completely fill out and sign the Hot Work Permit before commencing work. Employees and/or contractors’ personnel shall obtain Hot Work Permit approval from the site supervisor. Before the Hot Work Permit is approved, the following steps must be completed:
A. The production or process equipment must be prepared and isolated in accordance with applicable Lockout/Tagout (LOTO), Confined Space, and fire safety procedures. See Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Lockout/Tagout (LOTO) Program and Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Confined Space Entry Program for requirements related to LOTO and Confined Space operations.
B. The Hot Work Permit must be reviewed with all employees and/or contractors’ personnel involved in the work and approval process. Site supervisors shall physically review the area and its conditions and designate precautions to be followed in granting authorization to proceed. Such precautions shall be included on the permit.
C. Applicable welder's qualifications must be met.
12-2017 Page 41 of 114
D. The area where the Hot Work is to be performed shall be made fire safe. If the object upon which Hot Work is to be performed cannot be readily moved, all movable fire hazards in the vicinity shall be moved to a safe place. If the object upon which Hot Work is to be performed cannot be readily moved and if all the fire hazards cannot be removed, then guards shall be used to confine the heat, sparks, and slag, and to protect the immovable fire hazards, and the following additional precautions shall be taken where applicable:
1. Where combustible materials such as paper clippings, wood shavings, or textile fibers are on the floor, the floor shall be swept clean for a radius of 35 feet.
2. Combustible floors shall be kept wet, covered with damp sand, or protected by fire-resistant shields. Where floors have been wet down, employees operating arc welding or cutting equipment shall be protected from possible shock.
3. Suitable fire extinguishing equipment shall be maintained in a state of readiness for instant use.
4. Hot Work shall not be permitted in the following areas:
a. areas not authorized by management;
b. buildings with sprinkler systems when such protection is impaired;
c. areas in the presence of explosive atmospheres (mixtures of flammable gases, vapors, liquids, or dusts with air), or explosive atmospheres that may develop inside unclean or improperly prepared tanks or equipment which may have previously contained such material or that may develop in areas with an accumulation of combustible dusts; and
d. areas near the storage of large quantities of exposed, readily ignitable materials such a bulk sulphur, baled paper, or cotton.
5. Where practicable, all combustibles shall be relocated at least 35 feet from the work area. Where relocation is impractical, combustibles shall be protected with flameproof covers or otherwise shielded with metal guards or curtains.
6. Ducts and conveyors systems that might carry sparks to distant combustibles shall be suitably protected or shut down.
7. When Hot Work is to be done near walls, partitions, ceiling or roof of combustible construction, fire resistant shields shall be provided
12-2017 Page 42 of 114
to prevent ignition.
8. If Hot Work is to be done on a metal wall, partition, ceiling or roof, precautions shall be taken to prevent ignition of combustibles on the other side, due to conduction or radiation, preferably by relocating the combustibles. If combustibles are not relocated, a “Fire Watcher,” an employee designated to watch for fires, shall be placed on the opposite side of the work.
9. Hot Work shall not be performed on a metal wall, partition, ceiling or roof having a combustible covering or on combustible walls or partitions of combustible sandwich type panel construction.
10. Hot Work shall not be performed on pipes or other metal in contact with combustible walls, partitions, ceilings or roofs if the work is close enough to cause ignition by conduction.
11. Hot Work shall not be performed on used drums, barrels, tanks, or other containers until they have been cleaned so thoroughly as to make absolutely certain that there are no flammable materials present of any substances such as greasers, tars, acids, or other materials which when subjected to heat might produce flammable or toxic vapors. Any pipelines 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.
12. When arc welding is to be suspended for any substantial period of time, such as during lunch or overnight, all electrodes shall be removed from the holders and the holders carefully located so that accidental contact cannot occur, and the machine shall be disconnected from the power source.
13. In order to eliminate the possibility of gas escaping through leaks or improperly closed valves, when gas welding or cutting, the torch valves shall be closed and the gas supply to the torch positively shut off at some point outside the confined area whenever the torch is not to be used for a substantial period of time, such as during lunch hour or overnight. Where practicable, the torch and hose shall also be removed from the Confined Space.
E. An employee shall be designated to act as a Fire Watcher whenever welding or cutting is performed in locations where other than a minor fire might develop, or any of the following conditions exist:
1. appreciable combustible material in building construction or contents, closer than 35 feet to the point of operations;
12-2017 Page 43 of 114
2. appreciable combustibles more than 35 feet away but easily ignited by sparks;
3. wall or floor openings within a 35-foot radius expose combustible materials in adjacent areas, including concealed spaces in walls or floors; or
4. combustible materials adjacent to the opposite side of metal partitions, walls, ceilings, or roofs and likely to be ignited by conduction or radiation.
The Fire Watcher shall have proper fire extinguishing equipment and safety equipment and shall be trained in its use.
F. A welder or helper working on platforms, scaffolds or runways shall be protected against falling through the use of railings, safety belts, lifelines, or some other equally effective safeguards.
G. Welders shall place welding cable and other equipment so that it is clear of passageways, ladders and stairways.
H. A pre-job meeting must be conducted to communicate safety and health precautions to employees and/or contractors’ personnel performing the work. The employees and/or contractors’ personnel performing the work must sign the permit.
I. Necessary gas tests must be performed for explosiveness, toxicity or other hazardous conditions and a record of the readings must be on the Hot Work permit.
J. Welding equipment must be inspected for the following:
1. cracks, splits or loose connections in welding leads;
2. leaks in connections to oxygen or acetylene bottles, hoses and valves; and
3. installation of back flow valves.
K. Periodic checks of work in progress will be made with an explosimeter. The job will be shut down if combustible gases are found. Work will not be allowed to continue until the situation is corrected and a new Hot Work Permit has been issued.
L. Work areas and areas adjacent to the work areas will be inspected immediately after the completion of work to ensure no sparks have spread.
M. Completed Hot Work Permits will be kept on file at the nearest field office.
12-2017 Page 44 of 114
IV. PERMIT REQUIREMENTS
A. fire prevention and protection requirements are met prior to the commencement of the Hot Work operations;
B. date(s) for the authorized Hot Work;
C. identification of the object on which Hot Work is to be performed;
D. approval signatures; and
E. remain on file until the completion of Hot Work operations.
A copy of the Hot Work Permit form is located in Appendix 2: Forms and on the Company intranet.
V. RESPONSIBILITIES
A. Management
1. Ensure the safe usage of cutting and welding equipment on its property.
2. Based on fire potentials of plant facilities, establish areas for cutting and welding, and establish procedures for cutting and welding, in other areas.
3. Designate an individual responsible for authorizing cutting and welding operations in areas not specifically designed for such processes.
4. Insist that cutters or welders and their supervisors are suitably trained in the safe operation of their equipment and the safe use of the process.
5. Provide employees and/or contractors’ personnel with information concerning flammable materials or hazardous conditions.
B. Employee
The employee performing the work requiring the Hot Work Permit is responsible for fully completing and signing the permit and for coordinating the operations with his or her supervisor.
12-2017 Page 45 of 114
C. Supervisors
1. Verify that Hot Work Permit procedures are properly followed and completed.
2. Obtain proper signatures on the permit.
3. Warn other employees and/or contractors’ personnel in the vicinity not to perform operations which would change conditions that would void the permit or that would conflict with the permit conditions.
4. Stop work if a change occurs that can create an unsafe condition.
5. Inspect the work area after the work is complete.
6. Require the safe handling of cutting or welding equipment and safe use of the cutting or welding process.
7. Determine whether combustible materials are present or likely to be present in the work location.
8. Protect combustibles from ignitions by following the fire prevention and protection requirements listed in Permit Procedures.
D. Fire Watcher
1. Shall have fire extinguishing equipment and shall be trained in its use.
2. Shall be familiar with facilities for sounding an alarm in the event of a fire.
3. Watch for fires in all exposed areas and try to extinguish them only when obviously within the capacity of the equipment available, or otherwise sound the alarm.
4. Shall not perform other duties while "watching" for fires.
5. Stop the work if necessary and alert all employees and/or contractors’ personnel entering the permitted area of the potential hazards.
6. Maintain a fire watch for at least 30 minutes after completion of welding or cutting operations to detect and extinguish possible smoldering fires.
12-2017 Page 46 of 114
E. Contractors
1. Ensure that their personnel are aware of all Company safety policies, the contents of this section and applicable local, state, and federal laws and regulations.
2. Maintain a permanent record of personnel used which shows compliance with applicable federal, state or local laws and regulations for the type of work being performed (e.g., pipeline, pressured vessels.
12-2017 Page 47 of 114
12. SAFE WORK OPERATIONS
I. PURPOSE/SCOPE
The scope of this section is to establish procedures for communicating potential safety and environmental hazards that may be encountered during work on Company field locations.
II. GENERAL POLICY
A. Safe Work Permits
1. The site supervisor is responsible for communicating current operating conditions and associated hazards to employees conducting non-routine operations and to contractors working at Company field locations. These conditions and hazards will be documented on a Safe Work Permit. A copy of the Perdure TRP Safe Work Permit/JSA form is provided in Appendix 2: Forms.
2. The completed Safe Work Permit will be provided to employees and/or contractors to review prior to beginning operations. Typically, this would occur during site orientation and/or check in.
3. The completed Safe Work Permit will be kept onsite by the site supervisor for the duration of the job
B. Simultaneous Operations (SIMOPS)
1. When employees are performing major construction, well work, or drilling on an active Company production site at the same time other employees or contractors are performing such work, and these simultaneous operations create an additional hazard not described in the safe work permit, the site supervisor is responsible for insuring that everyone is aware that there are SIMOPS and that they impose additional hazards to company and contractor personnel. The key element during SIMOPS is communication. It is imperative that clear and continuous communication be maintained between company personnel as well as other contractor or service personnel on site. A Company production site is considered “active” if wells will remain on production during the construction, well work, or drilling activity.
2. In the event additional hazards are created, the site supervisor shall insure that a SIMOPS plan or either a new or modified safe
12-2017 Page 48 of 114
work permit is in place before operations commence. The SIMOPS plan or safe work permit will include a description of the additional hazards created by the simultaneous operations and mitigation measures (e.g. safety devices, alarms, emergency shut downs) taken by the Company to reduce the risk of such hazards.
3. A copy of the SIMOPS plan or safe work permit shall be retained onsite for the duration of the operations and made available for review.
12-2017 Page 49 of 114
13. SHORT SERVICE EMPLOYEE (SSE)
I. PURPOSE/SCOPE
A newly hired employee, an employee promoted to a new position in the Company, or an employee relocated to a new site, each of whom have not yet demonstrated competence of Company safety policies for their work environment, regardless of prior experience, shall be designated as an SSE.
According to accident statistics, SSE’s are more likely to experience an accident involving a work-related injury or illness. This section provides guidance in protecting this category of employee and will be followed when dealing with SSE’s.
II. GENERAL POLICY
Refer to the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Short Service Employee (SSE) Program for specific requirements. A copy of the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Short Service Employee Program is located in Appendix 1: Programs.
A. Each SSE must clearly understand his or her responsibilities to safety. There are specific policies and standards that must be understood in order to assure the safety of the employee as well as their co-workers.
B. The site supervisor or his designee will be responsible for insuring the training and mentoring of each new SSE.
C. Supervisors will not assign an SSE to a job in which that individual has not successfully completed all required training. The SSE may be asked to apprentice or assist his or her mentor so he or she can gain on-the-job experience.
D. After appropriate training requirements have been met, the employee must demonstrate their competence to perform a task to the satisfaction of his or her supervisor prior to engaging in a task unattended. Documented training will be maintained by the Operations Department or at the work location.
12-2017 Page 50 of 114
14. DRILLING AND WORKOVER RIG SAFETY
I. PURPOSE/SCOPE
Drilling and workover operations are typically performed by contractors. The purpose of this section is to reference the necessary contracts and industry standards for drilling and workover operations.
II. GENERAL POLICY
A. Company employees shall hire contractors who will adhere to OSHA, industry, and Company standards. Any additional special safety precautions shall be covered in the Drilling Contract, MSA, or workover procedure.
B. Company employees and/or contractors’ personnel involved with drilling or workover operations will be familiar with and follow the safe practices set forth by industry standards (e.g. International Association of Drilling Contractors Health, Safety and Environmental Reference Guide and American Petroleum Institute) and OSHA.
C. The site supervisor and/or contractor supervisor shall be certified in Well Control Operations. Current certificates must be made available for review.
D. The site supervisor will notify contractors of those additional conditions or hazards that may impact the area of the wellsite prior to contractors beginning drilling or workover operations.
12-2017 Page 51 of 114
15. EXCAVATION, TRENCHING AND SHORING
I. PURPOSE/SCOPE
This section provides requirements and guidelines for excavation, trenching and shoring operations.
II. GENERAL POLICY
A. Excavation, trenching, and shoring operations will be conducted in accordance with 29 CFR 1926.650, 29 CFR 1926.651, and 29 CFR 1926. 652.
B. Prior to commencing any excavation operations, the following steps shall be taken to prepare the work area for excavation operations:
1. Prior to commencing excavation operations, a work plan will be submitted to the site supervisor. The plan must be coordinated with any and all contractors with equipment in the area or working in the area.
2. The entire area to be excavated must be surveyed and all existing line crossings staked. Prior to opening an excavation, the Company shall determine the estimated location of utility installations, or any other underground installations that reasonably may be expected to be encountered during excavation work. The utility companies or owners of the underground installations shall be contacted within established or customary response times, advised of the proposed work, and asked to establish the location of the underground installations prior to start of actual excavation work. When utility companies or owners cannot respond to a request to locate underground installations within 24 hours (unless a longer period is required under state law) or cannot establish the exact location of the installations, the Company may proceed with the excavation work as long as it does so with caution and uses detection equipment or other acceptable means to locate the installations such as metal line finders. When excavation operations approach the estimated location of underground installations, the exact location of the installations shall be determined by safe and acceptable means. When underground utilities cannot be positively identified, all attempts should be made to de-energize the utility.
3. State laws and regulations pertaining to excavation notifications shall be followed (“Call Before You Dig”, “One Call”, etc.). In most areas, the 811 notification procedures have been implemented.
12-2017 Page 52 of 114
The 811 number will direct the caller to the local excavation notification system.
4. Digging around line crossings to locate and establish depth and direction of any and all other lines (including buried cables, lateral line takeoffs or other lines in the defined area to be excavated) shall be done by hand.
5. If red concrete is encountered, extreme caution is necessary, since this is used to indicate buried electrical wiring.
C. While the excavation is open, underground installations shall be protected, supported or removed as necessary to safeguard employees
D. Supervisors shall identify existing and reasonably expected hazards related to excavation, trenching and shoring operations.
E. Trenches or excavations exceeding 4 feet in depth and containing an oxygen deficient atmosphere or hazardous atmosphere, or which could reasonably be expected to contain such an atmosphere shall be tested prior to entry by employees. Adequate precautions such as providing respiratory equipment or ventilation shall be taken to prevent employee exposure to an oxygen deficient atmosphere or other hazardous atmosphere. When controls are used to reduce the level of atmospheric contaminants to acceptable levels, testing shall be conducted as often as necessary to ensure that the atmosphere remains safe.
F. Any open trenches or excavations shall be properly barricaded and marked and, at night, marked with reflectors or lights.
G. Employees shall be provided with a convenient escape route. A stairway, ladder, or ramp or other safe means of escape shall be located in trench excavations that are 4 feet or more in depth so as to require no more than 25 feet of lateral travel for employees.
III. PROTECTIVE SYSTEMS
A. Employees performing work in a trench or excavation shall be protected from cave-ins by an adequate protective system. Protective systems are not required when excavations are made entirely in stable rock; or excavations are less than 5 feet in depth and examination of the ground provides no indication of a potential cave-in.
B. Protective systems shall have the capacity to resist without failure all loads that are intended or could reasonably be expected to be applied or transmitted to the system.
C. Protective systems include support systems, sloping and benching
12-2017 Page 53 of 114
systems, shield systems and other systems that provide the necessary protection. The slopes and configurations of sloping and benching systems and the designs of support systems, shield systems, and other protective systems shall be selected and constructed in accordance with the requirements of 29 CFR 1926.652.
D. Materials and equipment used for protective systems shall be free from damage or defects. Manufactured materials and equipment shall be used and maintained in a manner that is consistent with manufacturer recommendations and in a manner that will prevent employee exposure to hazards. Damaged materials or equipment shall be removed from service if they are not able to support intended loads or are not otherwise suitable for safe use. A registered professional engineer shall evaluate and approve the materials or equipment before they may be returned to service.
E. Support Systems
1. A support system is a structure such as underpinning, bracing, or shoring, which provides support to an adjacent structure, underground installation, or the sides of an excavation.
2. Members of support systems shall be securely connected together to prevent sliding, falling, kickouts, or other predictable failure.
3. Support systems shall be installed and removed in a manner that protects employees from cave-ins, structural collapses, or from being struck by members of the support systems. Individual members of support systems shall not be subjected to loads exceeding the individual designed limits.
4. Before temporary removal of individual members begins, additional precautions shall be taken to ensure the safety of all employees.
5. Removal shall begin at, and progress from, the bottom of the excavation. Members shall be released slowly so as to note any indication of failure of the remaining members of the structure or possible cave-in at the sides of the excavation.
6. Backfilling shall progress together with the removal of support systems from excavations.
7. Excavation of material to a level no greater than 2 feet below the bottom of the members of the support systems shall be permitted, but only if the systems is designed to resist the forces calculated for the full depth of the trench, and there are no indications while the trench is open of a possible loss of soil from behind or below the bottom of the support system.
12-2017 Page 54 of 114
8. Installation of a support system shall be closely coordinated with the excavation of trenches.
F. Sloping and benching systems
1. A sloping system is a method of protecting employees from cave- ins by excavating to form sides of an excavation that are inclined away from the excavation so to prevent cave-ins. The angle of the incline varies with such factors are soil types, environmental conditions of exposures, and application of surcharge loads.
2. A benching system is 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.
3. Employees shall not be permitted to work on the faces of sloped or benched excavations at levels above other employees except when employees at the lower levels are adequately protected from the hazard of falling, rolling, or sliding material or equipment.
G. Shield systems
1. A shield system is a structure that is able to withstand the forces imposed on it by a cave-in and thereby protect employees within the structures. Shields can be permanent structures or can be designed to be portable and moved along as work progresses. Shields used in trenches are usually referred to as trench boxes or trench shields.
2. Shield systems shall not be subjected to loads exceeding those which the systems were designed to withstand.
3. Shields shall be installed in a manner to restrict lateral or other hazardous movement in the event of the application of sudden lateral loads.
4. Employees shall be protected from the hazard of cave-ins when entering or exiting the areas protected by the shields.
5. Employees shall not be allowed in shields when shields are being installed, removed, or moved vertically.
6. Excavations of earth material to a level not greater than 2 feet below the bottom of the shield shall be permitted, but only if the shield is designed to resist the forces calculated for the full depth of the trench and there are no indications while the trench is open of a possible loss of soil from behind or below the bottom of the shield.
12-2017 Page 55 of 114
16. FIRE SAFETY
I. PURPOSE/SCOPE
This section establishes safety procedures necessary to protect employees from fires or explosive hazards.
II. GENERAL POLICY
The Company will provide portable fire extinguishers at all Company locations and facilities for incipient stage fire (an initial or beginning stage fire) response and safe evacuation. The portable fire extinguishers shall be mounted, located and identified so that they are readily accessible to employees without subjecting them to possible injury. All employees in the fire area shall immediately evacuate the affected work area upon the sounding of the fire alarm. In addition, all Company vehicles will be equipped with fire extinguishers.
III. RESPONSIBILITIES
Responsibility for compliance with the requirements for fire hazard detection and fire prevention rests with each employee. In the event of a fire, immediately call 911 and activate the fire alarm.
Upon the sounding of the fire alarm, all employees shall immediately evacuate the work area in accordance with the site specific Emergency Response Plan.
Only trained employees are authorized to use portable fire extinguishers. Such employees shall only use the portable fire extinguishers for initial or beginning stage fire response and safe evacuation and shall not attempt to respond to a fire beyond the incipient stage.
See site specific Emergency Response Plan for additional employee responsibilities.
IV. FIRE HAZARDS
Efforts will be made to identify all fire hazards within a facility by performing each of the following activities:
A. Smoking will only be allowed in designated areas.
12-2017 Page 56 of 114
B. No smoking or open flames will be permitted where hydrocarbons are stored, or gas blankets exist unless a permissible smoking area has been established at a safe distance from sources of flammable materials.
C. Hot Work (such as welding, burning and other activities which produce sparks or flames or create hot surfaces) will be performed under controlled conditions and only after fire hazards have been eliminated or minimized and a properly authorized Hot Work Permit has been issued. Refer to Section 11, Hot Work for fire prevention and protection requirements during Hot Work.
D. Machinery inspection and maintenance will be performed on a regularly scheduled basis to discover and correct any mechanical problems which could create a fire hazard. All engines on drilling or workover rigs will be equipped with spark arresters. Any equipment that may have an ignition source will be operated in accordance with manufacturer’s specifications.
E. Proper housekeeping will be performed to eliminate or minimize the accumulation of combustible materials and any debris which could impede fire fighting or evacuation efforts.
1. Materials which are susceptible to spontaneous combustion will be properly disposed of and stored. For example, oily rags will be kept in covered metal containers situated well clear of any combustible areas, and iron sulfide scale will be kept wet until it can be properly disposed of.
2. Weeds and grass will be controlled inside of fire walls, around buildings, tanks, wells, heaters, and other vessels to prevent the possibilities of fire.
F. Hazardous materials will be properly handled and stored and will be used under controlled conditions in limited quantities away from sources of ignition with the appropriate fire extinguisher readily available.
G. Any leak of a flammable material such as natural gas, LP gas or gasoline will be stopped immediately by shutting off the fuel. Any potential sources of ignition such as nearby engines, fired equipment, welding operations, etc. will be shut down until the leak is repaired.
H. Static electricity, especially in dry climatic conditions, may cause fires and/or explosions. Care should be taken to minimize this risk. Static- proof containers will be used to transport or store flammable materials (e.g., metal buckets should be used at sample ports, bleed valves, etc.).
I. Oxygen under pressure forms an explosive mixture with oil and grease.
12-2017 Page 57 of 114
V. WELLSITE OPERATIONS
Site supervisors shall make adequate fire safety equipment available during well treating/workover and related maintenance activities.
VI. TRAINING
A. The Company will provide training in fire safety and evacuation.
B. Designated employees will be trained in the use of portable fire extinguishers. Training will include the general principles of fire extinguisher use and the hazards involved with incipient stage fire fighting and will be conducted upon initial employment and, at least, annually thereafter. It will also include the following classification of fires and type of extinguisher used on each:
1. Class A fires (ordinary combustible materials such as paper, wood, cloth and some rubber and plastic materials).
2. Class B fires (flammable or combustible liquids, flammable gases, greases and similar materials and some rubber and plastic materials).
3. Class C fires (energized electrical equipment where safety to the employee requires the use of electrically non-conductive extinguishing media). For fires involving de-energized electrical equipment, extinguisher for Class A or Class B may be used.
VII. FIRE EXTINGUISHER INSPECTION, MAINTENANCE, AND TESTING
A. Portable fire extinguishers shall be maintained in a fully charged and operable condition and kept in designated places at all times except during use.
B. All portable fire extinguishers shall be visually inspected monthly. Such inspections shall be documented.
C. Portable fire extinguishers shall be given annual maintenance checks. (Stored pressure extinguishers do not require an internal examination). The annual maintenance date shall be recorded. A record of the maintenance date will be kept for 1 year after the last maintenance date entry.
D. Stored pressure-dry chemical extinguishers requiring a 12-year hydrostatic test shall be emptied and subjected to applicable maintenance procedures every 6 years. (Dry chemical extinguishers with disposable containers are exempt from this requirement.) When recharging or
12-2017 Page 58 of 114
hydrostatic testing is performed, the 6-year requirement begins from that date.
E. An alternative means of protection shall be provided while extinguishers are removed from service for maintenance, recharging, testing, etc.
VIII. HYDROSTATIC TESTING OF FIRE EXTINGUISHERS
A. Hydrostatic testing shall be conducted in accordance with the requirements of 29 CFR 1910.157 (f) and shall only be performed by trained persons with suitable testing equipment and facilities.
B. Portable fire extinguishers shall be hydrostatically tested at the intervals listed in the following Table 16-1, except under the following conditions:
1. when the unit has been repaired by soldering, welding, brazing, or use of patching compounds;
2. when the cylinder or shell threads are damaged;
3. when there is corrosion that has caused pitting, including corrosion under removable name plate assemblies;
4. when the extinguishers have been burned in a fire; or
5. when calcium chloride extinguishing agent has been used in a stainless steel shell.
12-2017 Page 59 of 114
Table 16-1 Test Type of extinguishers interval (years) Soda acid (soldered brass shells) (until 1/1/82) * Soda acid (stainless steel shell) 5 Cartridge operated water and/or antifreeze 5 Stored pressure water and/or antifreeze 5 Wetting agent 5 Foam (soldered brass shells) (until 1/1/82) * Foam (stainless steel shell) 5 Aqueous Film Forming foam (AFFF) 5 Loaded stream 5 Dry chemical with stainless steel 5 Carbon dioxide 5 Dry chemical, stored pressure, with mild steel, brazed brass or aluminum shells 12 Dry chemical, cartridge or cylinder operated, with mild steel 12 shells Halon 1211 12 Halon 1301 12 Dry powder, cartridge or cylinder operated with mild steel 12 shells *Extinguishers having shells constructed of copper or brass joined by soft solder or rivets shall not be hydrostatically tested and shall be removed from service by January 1, 1982. (Not permitted)
C. In addition to an external visual examination, an internal examination of cylinders and shells to be tested shall be performed prior to the hydrostatic tests.
D. Portable fire extinguishers shall be hydrostatically tested whenever they show new evidence of corrosion or mechanical injury except as provided for in this section.
E. Extinguisher shells, cylinders, or cartridges which fail a hydrostatic pressure test, or which are not fit for testing, shall be removed from service and the workplace.
F. The date of the hydrostatic test, the signature of the person who performed the test and the serial number, or other identifier, of the fire
12-2017 Page 60 of 114
extinguisher that was tested shall be recorded. This hydrostatic test record shall be kept until the fire extinguisher is retested as provided in Table 16-1 above or until the extinguisher is taken out of service, whichever comes first.
IX. EMERGENCY RESPONSE
A. Emergency Response activities will be coordinated with the local Fire Department, Sheriff's Department and other emergency response organizations as necessary. Identification of hazardous materials content, along with MSDS information and hazards, will be made available to individuals responding to an emergency situation.
B. Emergency response exercises (e.g., fire drills, evacuation drills, etc.) will be conducted on an annual basis at workplaces that regularly staff more than 10 people.
X. FLAMMABLE/COMBUSTIBLE LIQUID STORAGE/USE
A. “Flammable liquid” means any liquid having a flashpoint below 100° F (37.8° C), except any mixture having components with flashpoints of 100° F (37.8° C) or higher, the total of which make up 99% or more of the total volume of the mixture. Flammable liquids shall be known as Class 1 liquids. Class 1 liquids are divided into 3 classes:
1. Class IA liquids have flashpoints below 73° F and have a boiling point below 100° F.
2. Class IB liquids have flashpoints below 73° F and have a boiling point at or above 100° F.
3. Class IC liquids have flashpoints at or above 73° F and below 100° F.
B. “Combustible liquid” means any liquid having a flashpoint at or above 100° F. Combustible liquids are divided into 2 classes:
1. Class II liquids have flashpoints at or above 100° F, except any mixture having components with flashpoints of 200° F or higher, the volume of which make up 99% or more of the total volume of the mixture.
2. Class III liquids have flashpoints at or above 140° F and are divided into the following subclasses:
a. Class IIIA liquids have flashpoints at or above 140° F and
12-2017 Page 61 of 114
below 200° F, except any mixture having components with flashpoints of 200° F or higher, the volume of which make up 99% or more of the total volume of the mixture.
b. Class IIIB liquids have flashpoints at or above 200° F
3. When a combustible liquid is heated for use to within 30° F of its flashpoint, it shall be handled in accordance with the requirements of the next lower class of liquids.
C. Flammable and combustible liquids shall be stored in accordance with 29 CFR 1910.106.
XI. ALARM SYSTEMS REQUIREMENTS
A. An alarm system meeting the following requirements shall be provided and maintained at each Company site:
1. The alarm system shall provide warning for necessary emergency action for safe escape of employees from the work area.
2. The alarm system shall be capable of being perceived above ambient noise or light levels by all employees in the affected portions of the workplace. Tactile devices may be used to alert those employees who cannot otherwise hear or see the alarm.
3. The alarm shall be distinctive and recognizable as a signal to evacuate the work area or perform actions under the emergency action plan.
B. The manual pull box alarms shall be the preferred means of reporting emergencies when available. When manual pull box alarms are not available, employees shall follow alternate site specific procedures (public address systems, radios or telephones). When telephones are used as a means of reporting emergencies, emergency telephone numbers shall be posted near telephones or employee notice boards, and other conspicuous locations. When communication systems are used as an alarm system, all emergency messages shall have priority over non- emergency messages.
C. Direct voice communication can be used for sites with 10 or fewer employees provided that all employees can hear the warning.
D. All manually operated actuation devices shall remain unobstructed, conspicuous and readily accessible.
12-2017 Page 62 of 114
E. Maintenance and Testing
1. All alarm systems shall be maintained in operating condition except when undergoing repairs or maintenance. Backup means of alarm, such as employee runners or telephones, shall be provided when alarm systems are out of service.
2. Power sources for alarms shall be checked and maintained to assure correct operation.
3. All servicing maintenance and testing of employee alarms shall be performed by persons trained in the designed operation and functions necessary for the reliable and safe operation of the system.
4. After each test or use of an alarm, the alarm shall be restored to normal operating condition.
5. Employee alarm systems shall be tested in accordance with OSHA 29 CFR 1910.165 and manufacturers’ specifications.
12-2017 Page 63 of 114
17. CARBON DIOXIDE (CO2) SAFETY
I. PURPOSE/SCOPE
This section provides guidance for CO2 safety. It is applicable to all CO2 facilities, pipelines, and any other locations where CO2 hazards may be present.
II. GENERAL INFORMATION
A. The two main CO2 hazards are:
1. asphyxiation from exposure to high concentrations of the gas; and
2. severe frostbite for skin contact with liquid or frozen CO2 or with vessels containing liquid or frozen CO2.
B. CO2 is not normally considered a toxic gas in the generally accepted sense of the term (i.e. poisonous). It is normally present in the atmosphere at a concentration of approximately 0.03%. If exposed to high concentrations of CO2 for extended periods of time, there are certain risks and health hazards that warrant attention. Some of these hazards, depending upon length of time and amount of CO2 a person is exposed to, are dizziness, sweating, deep breathing, headaches, frostbite, convulsions, unconsciousness and suffocation.
C. CO2 is heavier than air (specific gravity of 1.53 @ 60° F), and when released to air generally emerges as a faint white cloud.
D. CO2 acts upon the body's vital functions in a number of ways, including respiratory stimulation, regulation of blood circulations and acidity of body fluids. Exposure to high concentrations of CO2 can cause discomfort, nausea and unconsciousness.
E. The current OSHA standard for maximum allowable concentration of CO2 in air is 0.5% (5,000 ppm) for 8 continuous hours of exposure. However, the National Institute for Occupational Safety and Health has recommended the limit be set at 1.0% (10,000 ppm) for a10-hour shift in a 40-hour week.
F. As the CO2 concentration in the air increases, certain physical symptoms are felt which signal the degree of danger to which one is being exposed:
1. Up to about 1.5% CO2 in the air, there are no noticeable physical symptoms for about 1 hour. Most people could probably be exposed to 1.5% CO2 for several hours with no ill effects.
12-2017 Page 64 of 114
However, when cold CO2 vapor is released in a humid atmosphere, the moisture condensing from the air forms a dense white fog which can be frightening, while not necessarily dangerous.
2. With 3% to 5% CO2 in the air, breathing becomes deeper and a little faster, and lightheadedness may be felt. If the person remains in this atmosphere for more than half an hour, he or she will probably become very uncomfortable and nauseous. These symptoms are good warnings to move into fresh air.
3. With 5% to 9% CO2 in the air, breathing becomes very deep, faster, and labored. The person becomes nauseous and dizzy quickly. When these symptoms occur, the he or she should immediately proceed to a source of fresh air.
4. Above 9% CO2 in the air, unconsciousness can occur in 5 to 10 minutes or less. People will experience very deep breathing, sickness, and dizziness very quickly.
5. With about 20% CO2 in the air, death is likely in 20 to 30 minutes unless the person is moved to fresh air.
G. For short-term exposures to very high CO2 concentrations, immediate removal of the person to fresh air can prevent irreversible physiological damage. However, in all situations where anyone is exposed to high concentrations of CO2, they should consult a physician before returning to work.
H. Because CO2 is heavier than air, pockets of high CO2 concentrations may persist in low places for some time. This is especially a possibility in open pits or in tanks, and these areas should be cleared by forced ventilation, or an air supply should be worn when entering them if the presence of CO2 is suspected.
I. Rapid reduction of system pressure will reduce the temperature of CO2, and this will cool equipment in contact with the CO2 so that a danger of frostbite or even freezing of the skin to equipment could exist. Generally, equipment that is cooled to this point will be coated with a layer of frost caused by freezing of moisture which condenses from the air.
III. PHYSICAL CHARACTERISTICS OF CO2
A. CO2, at ambient temperatures and pressures, is a colorless gas with a slightly pungent (causing a sharp or irritating sensation) odor and acid taste at high concentrations. It also exists as a solid (dry ice), and at the right combinations of temperature and pressure is a liquid.
12-2017 Page 65 of 114
B. To become a liquid, CO2 must be under pressure of at least 75.14 PSIA. Below 55.14 PSIA, CO2 vapor and solids (dry ice) will form. Above the critical temperature point of 87.9° F, it is impossible to liquefy the gas by increasing the pressure above the corresponding critical pressure of 1071 PSIA. Above the CO2 critical pressure, the phase is called supercritical fluid and is of great advantage in pipeline transportation. Most long distance CO2 pipelines operate above the critical pressure.
C. Although CO2 will remain in a single phase above the critical pressure of 1071 PSIA, there can be significant changes in the density. For example, at 100° F and 1200 PSI, the density of CO2 is +23 LB/FT3, at 60° F and 1200 PSI, the density is +54 LB/FT3.
D. The normal temperature of dry ice is -109° F. Above this temperature and at 1 atmosphere, the solid changes directly back to a gas.
E. The critical temperature of CO2 (highest temperature at which CO2 can exist as a liquid) is 87.9° F. The critical pressure of CO2 (highest pressure at which CO2 can exist as a gas) is 1056 PSIG.
F. The temperature of solid CO2 at atmospheric pressure is -109.3° F.
IV. FIRST AID FOR PERSONS EXPOSED TO HIGH CONCENTRATIONS OF CO2
A. If an employee is exposed to high concentration of CO2, immediately seek emergency medical treatment.
B. While awaiting emergency medical treatment, the following first aid treatments may be rendered:
1. If a person exposed to a high concentration of CO2, is still conscious and capable of functioning, the person should be moved into fresh air and kept under observation.
2. Unconscious or mentally confused persons should be taken into fresh air and treated with a respirator or should receive other emergency treatment as demanded by the circumstances, such a cardiopulmonary resuscitation (CPR).
V. FIRST AID FOR FROSTBITE
A. If an employee has suffered frostbite, immediately seek emergency medical treatment.
B. While awaiting emergency medical treatment, the following first aid treatments may be rendered:
12-2017 Page 66 of 114
1. Warm the frozen body area immediately by immersion in warm water of about 102° to 105° F. If possible, immerse the entire body. Do not use water hotter than 105° F. The frozen area is highly susceptible to heat burn. Do not touch, or allow the victim to touch, the affected area.
2. If warm water is not available or practicable for treating the burn, gently wrap the affected area in a clean, re-warmed blanket. Change the blanket as necessary. If the injury is extensive, wrap the entire body of the employee in warm blanket. If possible, a second person should be wrapped in the blanket with the victim to provide additional body warmth.
3. Hot drinks, such as coffee, are advised to help preserve body temperature. Do not allow the employee to drink alcohol.
4. Do not apply oils or alcohol to the injured area. Cover the area with sterile gauze only.
5. Do not allow an employee with frostbitten feet to walk.
12-2017 Page 67 of 114
18. HYDROGEN SULFIDE (H2S) SAFETY
I. PURPOSE/SCOPE
The Hydrogen Sulfide (H2S) Safety Policy can be found in Appendix 1: Programs. All operations in areas exposed to H2S are to be conducted in compliance with the H2S Safety Policy. The purpose of this section is to familiarize Company employees with hazards related to the accidental release of Hydrogen Sulfide (H2S) into the atmosphere and to provide employees with safe practices for working at sites where H2S hazards may be present.
II. GENERAL POLICY
A. The National Institute for Occupational Safety and Health (NIOSH) permissible exposure limit (PEL) concentration for H2S is 10 ppm. The OSHA PEL concentration for H2S is 20 ppm.
B. The National Institute for Occupational Safety and Health (NIOSH) IDLH concentration for H2S is 100 ppm.
C. Operations and training requirements in H2S environments shall be conducted in accordance with regulations and the site specific H2S Contingency Plan. The site specific H2S Contingency Plan includes the following safety precautions and requirements:
1. Clearly visible warning signs will be posted in areas where H2S gas may be present and on access roads or public streets as permitted by law.
2. Monitors and alarms shall be installed.
3. Wind direction equipment will be installed at prominent locations on or near the drilling, workover, test, or plant facility to indicate the wind direction at all times and the safe upwind areas in the event of an accidental release of H2S into the atmosphere.
4. Danger signals, such as signs and flags, shall be displayed to indicate the presence of elevated H2S concentrations.
5. A fence surrounding the entire facility will be installed to prevent unauthorized persons from entering the site.
6. Employees required to work in an H2S area will be trained prior to starting work in the H2S area.
7. The Company will provide necessary respiratory protection
12-2017 Page 68 of 114
equipment to employees whose job requires them to work and enter into H2S environments. Such respiratory protection equipment shall be readily accessible.
8. Employees shall wear breathing equipment if rescuing a person in an area suspected to be contaminated by H2S.
9. Employees shall be familiar with portable or continuous H2S gas detection equipment that is available for monitoring a condition which could result in the formation of a toxic atmosphere. Employees shall check out danger areas first with H2S detectors before allowing anyone to enter. Employees shall not try to determine the presence of gas by its odor.
10. Appropriate tests shall be made before anyone enters areas suspected of being contaminated by H2S. These tests shall be made after employees have put on self-contained breathing equipment.
11. In areas of high H2S concentrations, a two-man operation is required.
12. Employees shall be familiar with the hazards concerning H2S and how to avoid them.
13. To minimize exposure to H2S, employees shall work on the windward side and have a fresh air mask available. Employees shall avoid low lying areas where H2S is likely to accumulate.
14. Employees should wear respirator equipment when gauging tanks, etc. and should never try to hold their breath in order to enter a contaminated atmosphere.
15. Employees shall wear proper respiratory equipment for the job at hand and shall never take a chance with equipment with which they are unfamiliar. If in doubt, employees shall consult their supervisors.
16. Employees shall never enter a tank, cellar or other enclosed place where gas can accumulate without proper respiratory protective equipment and a safety belt secured to a life line held by another person located outside the enclosed place.
17. Care shall be taken to prevent the escape of H2S fumes into the air of work areas by leaks, etc.
18. In areas where H2S may be present, a form of communications will be provided to contact emergency personnel.
12-2017 Page 69 of 114
19. ELECTRICAL SAFETY
I. PURPOSE/SCOPE
This section defines requirements and guidelines for safely working around or near electrical equipment.
II. GENERAL POLICY
Employees will strictly adhere to the safety related work practices and procedures outlined in this section.
A. Electrical equipment, cords, circuits and connections will be free from recognized hazards that are likely to cause death or physical injury to employees as specified in 29 CFR 1910.331-335.
B. Only Qualified Persons authorized by the Company shall work on electrical systems. For purposes of this section, a Qualified Person is employee or contractors’ personnel who has received training in avoiding the electrical hazards of working on or near exposed energized parts. An Unqualified Person is one who has little or no such training. All persons performing work on electrical systems shall have a valid and current license to perform such work when required by state law.
C. Unsafe electrical equipment, including appliances and lines, should be reported to a supervisor.
D. All electrical equipment shall be properly grounded.
E. All employees should be familiar with the operation of each electrical device they use.
III. PROCEDURES
The following safety related work practices reduce the risk of electric shock or other injuries resulting from either direct or indirect contact with energized equipment, circuits or cords.
A. De-Energizing and Locking Out and Tagging Out Live Parts
1, Live parts will be de-energized before an employee works on or near them.
12-2017 Page 70 of 114
2. The circuits and equipment to be worked on shall be disconnected from all electric energy sources. Control circuit devices such as push buttons, selector switches, and interlocks, may not be used as the sole means for de-energizing circuits or equipment. Interlocks for electric equipment may not be used as a substitute for lockout and tagout (LOTO) procedures. Stored electric energy shall be released. Capacitors shall be discharged, and high capacitance elements shall be short-circuited and grounded, where there is potential exposure to employees. Stored non- electrical energy in devices that could reenergize electric circuit parts shall be blocked or relieved to the extent that the circuit parts could not be accidentally energized by the device.
3. See Section 9, Lockout/Tagout (LOTO) and the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Lockout/Tagout (LOTO) Program for specific LOTO procedures.
B. Working on or Near Energized Parts
1. Only Qualified Persons may work on electrical circuit parts or equipment that have not been de-energized under the procedures set forth in Section 9, Lockout/Tagout (LOTO) and the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Lockout/Tagout (LOTO) Program. Such persons shall be capable of working safely on energized circuits and shall be familiar with the proper use of special precautionary techniques, personal protective equipment (PPE), insulating and shielding materials, and insulated tools.
2. If work will be performed near overhead lines, the lines shall be de-energized and grounded or other protective measures shall be provided before work is started. If the lines will be de-energized, arrangements shall be made with the person or organization that operates or controls the electric circuits to de-energize and ground them. Protective measures shall be designed to prevent bodily contact with such lines or indirect contact through conductive materials, tools, or equipment.
a. When an Unqualified Person is working near overhead lines, whether in an elevated position or on the ground, the location shall be such that the person and the longest conductive object he or she may contact cannot come closer to any unguarded, energized overhead line than the following distances: (i) For voltages to ground 50kV or below--10 feet; and (ii) For voltages to ground over 50kV-- 10 feet plus 4 inches for every 10kV over 50kV.
b. When a Qualified Person is working in the vicinity of overhead lines, whether in an elevated position or on the
12-2017 Page 71 of 114
ground, the person may not approach or take any conductive object without an approved insulating handle closer to the exposed energized parts than as shown in the following Table 19-1:
TABLE 19-1 MINIMUM APPROACH DISTANCES FOR QUALIFIED EMPLOYEES TO ENERGIZED ALTERNATING CURRENTS
Voltage Range Minimum (phase to phase) Approach Distance (in feet) 300 V and less avoid contact Over 300 V, but less than 750 V 1.0 Over 750 V, but less than 2 kV 1.6 Over 2 kV, but less than 15 kV 2.0 Over 15 kV, but less than 37 kV 3.0 Over 37 kV, but less than 87.5 kV 3.6 Over 87.5 kV, but less than 121 kV 4.0 Over 121 kV, but less than 140 kV 4.6
c. Any vehicle or mechanical equipment capable of having part of its structure elevated near energized overhead lines shall be operated so that a clearance of 10 feet is maintained. If the voltage is higher than 50kV, the clearance shall be increased 4 inches for every 10kV over that voltage. Employees standing on the ground may not contact the vehicle or mechanical equipment or any of its attachments, unless: (i) the employee is using protective equipment rated for the voltage; or (ii) the equipment is located so that no uninsulated part of its structure (that portion of the structure that provides a conductive path to employees on the ground) can come closer to the line than permitted in this section. If any vehicle or mechanical equipment, capable of having part of its structure elevated near energized overhead lines, is intentionally grounded, employees working on the ground near the point of grounding may not stand at the grounding location whenever there is a possibility of overhead line contact.
12-2017 Page 72 of 114
Additional precautions, such as the use of barricades or insulation, may be taken to protect employees from hazardous ground potentials, depending on earth resistivity and fault currents, which can develop within the first few feet or more outward from the grounding point.
3. Employees may not enter work spaces containing exposed energized parts unless illumination is provided that enables the employees to perform the work safely. Where lack of illumination or an obstruction precludes observation of the work to be performed, employees may not perform tasks near exposed energized parts. Employees may not reach blindly into areas which may contain energized parts.
4. Work in Confined Spaces or enclosed areas that contain energized parts will require the use of protective clothing, barriers, and/or shields as necessary. Doors, hinged panels, and the like shall be secured to prevent their swinging into an employee and causing the employee to contact exposed energized parts.
5. Conductive materials and equipment that are in contact with any part of an employee’s body shall be handled in a manner that will prevent them from contacting exposed energized conductors or circuit parts. If an employee must handle long dimensional conductive objects such as ducts and pipes in areas with exposed live parts, the employee shall use proper PPE as set forth in “Electrical Protective Equipment and Other Protective Measures” below.
6. Portable ladders shall have nonconductive side rails if they are used where the employee or the ladder could contact exposed energized parts.
7. Where live parts present an electrical contact hazard, employees will not perform housekeeping duties at such close distances to the parts that there is a possibility of contact. Electrically conductive cleaning materials, including conductive solids such as steel wool, metalized cloth, and silicone carbide, as well as conductive liquid solutions, may not be used in proximity to energized parts unless procedures are followed which will prevent electrical contact.
C. Electrical Protective Equipment and Other Protective Measures
1. Employees working in areas where there are potential electrical hazards shall be provided with and shall use electrical protective equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed. Employees shall wear nonconductive head protection wherever there is danger of
12-2017 Page 73 of 114
head injury from electric shock or burns due to contact with exposed energized parts. Employees shall wear protective equipment for the eyes and face where there is a danger of injury to eyes or face from electric arcs or flashes or from flying objects resulting from electrical explosion.
2. Electrical protective equipment shall be designed to meet the requirements set forth in 29 CFR 1910.137 (a). Electrical protective equipment meeting the following standards is deemed to be in compliance with 29 CFR 1910.137: American Society for Testing and Materials (ASTM) D 120-87, ASTM D178-93 (or 178-88), ASTM D 1048-93 (or 1048-88a), ASTM 1049-93 (or 1049-88), ASTM 1050-90, ASTM 1051-87.
3. Electrical protective equipment shall be maintained in a safe, reliable condition.
4. The following requirements apply to insulating blankets, covers, line hoses, gloves, and sleeves made of rubber:
a. Maximum use voltages shall conform to those listed on Table 19-2, “Rubber Insulating Equipment Voltage Requirements.”
b. Insulating equipment shall be inspected for damage before each day’s use and immediately following any incident that can reasonably be suspected of having caused damage to the equipment. An air test shall be performed on insulating gloves along with the inspection. Insulating equipment with any of the following defects may not be used and shall be removed from service and returned to testing.
(i) hole, tear, puncture, or cut;
(ii) ozone cutting or ozone checking;
(iii) embedded foreign object;
(iv) texture change such as swelling, softening, hardening, or becoming sticky or inelastic; or
(v) any other defect that damages the insulating properties.
c. Insulating equipment shall be tested periodically at the test voltages and for the maximum intervals set forth in Table 19-2 and Table 19-3.
d. The test method must reliably indicate whether the
12-2017 Page 74 of 114
insulating equipment can withstand the voltages involved.
e. Insulating equipment failing to pass inspections or electrical tests shall not be used, except in the following circumstances:
(i) Rubber insulating line hoses may be used in shorter lengths with the defective portion cut off;
(ii) Rubber insulating blankets may be repaired using a compatible patch that results in physical and electrical properties equal to those of the blanket.
(iii) Rubber insulating blankets may be salvaged by severing the defective areas from the undamaged portion of the blanket. The undamaged area may not be smaller than 22 by 22 inches for Class 1, 2, 3, and 4 blankets.
(iv) Rubber insulating gloves and sleeves with minor physical defects such as small tears and punctures may be repaired with a compatible patch. Minor surface blemishes to such gloves and sleeves may be repaired with a compatible liquid compound. Any patched area shall have physical and electrical properties equal to those of the surrounding material. Gloves may only be repaired in the area between the wrist and the reinforced edge of the opening.
f. Insulating equipment that has been repaired shall be retested before it may be used. The Company shall certify that the test was performed in accordance with the requirements of this section. The certification shall contain the identification of the equipment tested and the date it was tested.
g. Insulating equipment shall be cleaned as needed to remove foreign substances and shall be stored in a location to protect it from light, temperature extremes, excessive humidity, ozone, and other injurious substances and conditions.
h. Protector gloves shall be worn over insulating gloves except in the following situations:
(i) Protector gloves do not need to be used with Class 0 gloves where small equipment and parts manipulation require high finger dexterity.
12-2017 Page 75 of 114
(ii) Any other class of gloves may be used for similar work if it can be demonstrated that the possibility of physical damage to the gloves is very small and that the class of glove is one class higher than that required for the voltage involved. Insulating gloves that have been used without protector gloves may not be used for a higher voltage until they have been tested in accordance with this section.
TABLE 19-2 RUBBER INSULATING EQUIPMENT VOLTAGE REQUIREMENTS* Maximum Retest Retest Class of Use Voltage Voltage Voltage Equipment n1 a-c-rms n1 a-c-rms n2 d-c-avg 0 1,000 5,000 20,000 1 7,500 10,000 40,000 2 17,000 20,000 50,000 3 26,500 30,000 60,000 4 36,000 40,000 70,000 *The maximum use voltage is the a-c voltage (rms) classification of the protective equipment that designates the maximum nominal design voltage of the energized system that may be safely worked. The nominal design voltage is equal to the phase-to-phase voltage on multiphase circuits. However, the phase-to-ground potential is considered to be the nominal design voltage.
TABLE 19-3 RUBBER INSULATING EQUIPMENT TESTING INTERVALS* Type of Maximum Use Voltage Equipment n1 a-c-rms Rubber insulating Upon indication that insulting value line hose is suspect Rubber insulating Upon indication that insulating covers value is suspect Rubber insulating Before first issue and every 12 blankets months thereafter Rubber insulating Before first issues and every 6 gloves months thereafter Rubber insulating Before first issue and every 12 sleeves months thereafter *If the insulating equipment has been electrically tested but not issued for service, it may not be placed into service unless it has been electrically tested within the previous 12 months.
12-2017 Page 76 of 114
5. Conductive articles of jewelry and clothing, such as watchbands, bracelets, rings, key chains, necklaces, metalized aprons, cloth with conductive thread, or metal headgear, may not be worn if they might contact exposed energized parts or equipment.
6. When working near exposed energized conductors or circuit parts, employees shall use insulated tools or handling equipment if the tools or handling equipment might contact such conductor or parts. Fuse handling equipment, insulated for the circuit voltage, shall be used to remove or install fuses when the fuse terminals are energized. Ropes and hand lines used near exposed energized parts shall be nonconductive.
7. If the insulating capability of protective equipment, tools, or handling equipment may be subject to damage, the insulating material shall be protected.
8. Protective shields, protective barriers or insulating materials will be used to protect each employee from shock, burns or any other electrically related injury.
9. All live or energized equipment parts will be properly guarded by approved enclosures. When normally enclosed parts are exposed for maintenance or repair, they shall be guarded to protect Unqualified Persons from contact with the live parts.
10. The following alerting techniques will be used to warn and protect employees from hazards which could cause injury due to electric shock, burns, or failure of equipment parts:
a. safety signs, symbols, and tags;
b. barricades shall be used in conjunction with safety signs, symbols, and tags, to prevent or limit access to work areas where employees may be exposed to uninsulated energized conductors or circuit parts. Conductive barricades may not be used where they might cause an electrical contact hazard; and
c. attendants (if signs and barricades are not sufficient).
11. Employees authorized to work on electrical circuits shall be trained in CPR and first aid.
12. Illumination shall be provided where needed for all working spaces.
13. All live or energized equipment parts will be properly guarded by approved enclosures.
12-2017 Page 77 of 114
14. Electrical installations will be accessible and maintained only by Qualified Personnel.
15. Wiring will be designed, installed and maintained only by a Qualified Person and will be properly insulated to protect all workers from shock or burn.
16. Circuit and conductor disconnection will be performed only by a Qualified Person.
17. Proper grounding requirements will be strictly followed for all systems, circuits and equipment. Flexible cords used with grounding-type equipment will contain an equipment grounding conductor. Adapters which interrupt the continuity of the equipment grounding connection may not be used.
D. Use of Equipment
1. Portable electrical equipment shall be handled in a manner that will not cause damage. Flexible electric cords connected to equipment shall not be used for raising or lowering the equipment. Flexible cords may not be fastened with staples or otherwise hung in such a fashion as could damage the outer jacket or insulation. Portable electric equipment will be visually inspected prior to each use. Defective portable electric equipment will be removed from service and shall not be used until repairs are complete. When an attachment plug is to be connected to a receptacle, the relationship of the plug and receptacle shall be checked to ensure they are the proper mating configuration.
2. Proper grounding requirements will be strictly followed for all systems, circuits and equipment. Flexible cords used with grounding-type equipment will contain an equipment grounding conductor. Attachment plugs and receptacles may not be connected or altered in a manner which would prevent the proper continuity of the equipment grounding conductor at the point where plugs are attached to receptacles. These devices may not be altered to allow the grounding of a plug to be inserted into slots intended for connection to the current-carrying conductors. Adapters which interrupt the continuity of the equipment grounding connection may not be used.
3. Electrical equipment or cords will not be used in highly conductive work areas (e.g., wet areas or areas with other conductive media present on floor or wall surfaces). Care will be taken to ensure that employees do not have wet hands when plugging or unplugging electrical equipment. Energized plug and receptacle connections may only be handled with insulating protective equipment.
12-2017 Page 78 of 114
4. When operating in an area with flammable or ignitable materials such as gases, vapors or liquids, or combustible dust, use only equipment designated for use in that environment. The National Electrical Code NFPA (70) provides guidelines for selecting this equipment.
5. Locking type connectors shall be properly secured after connection.
6. Electrical interlocks will not be rendered inoperative by removal, modification or destruction.
7. Load rated switches, circuit breakers, or other devices specifically designed as disconnecting means shall be used for the opening, reversing, or closing of circuits under load conditions. Cable connectors not the load-break type, fuses, terminal lugs, and cable splice connections may be used for such purposes, except in an emergency. After a circuit is de-energized by a circuit protective device, the circuit may not be manually reenergized until it has been determined that the equipment and circuit can be safely energized. The repetitive manual reclosing of circuit breakers or reenergizing circuits through replaced fuses is prohibited.
8. Qualified Persons shall visually inspect all test instruments and equipment before the equipment is used. Any defective or damaged equipment shall be removed from service and shall not be used until repairs have been completed. Test instruments and equipment and their accessories shall be rated for the circuits and equipment to which they will be connected and shall be designed for the environment for which they will be used.
E. Miscellaneous Procedures
1. Prior to any trenching, tunneling or digging, buried power cables will be located and de-energized. When available, excavation notification protocols will be followed for any trenching operations involving electrical components.
2. Electrical installations will be accessible and maintained only by Qualified Personnel.
3. Wiring will be designed, performed and maintained only by Qualified Personnel and will be properly insulated to protect all workers from shock or burn.
4. Circuit and conductor disconnection will be performed only by Qualified Personnel.
12-2017 Page 79 of 114
IV. TRAINING
A. Employees shall be trained in and familiar with the safety-related work practices set forth in this Policy. Unqualified Persons shall also be trained in, and familiar with, any other electrically-related safety practices necessary for their safety.
B. Qualified Persons whose work on energized equipment involves either direct contact or indirect contact by means of tools or materials must also have the training specified in the procedures for working on or near exposed parts specified in this section, including:
1. skills and techniques necessary to distinguish exposed live parts from other parts of electric equipment;
2. skills and techniques necessary to determine the nominal voltage of exposed live parts; and
3. clearance distances specified in this section and the corresponding voltages to which the Qualified Person will be exposed.
12-2017 Page 80 of 114
20. MATERIALS HANDLING
I. PURPOSE/SCOPE
The section defines policies for safely and effectively handling and storing materials. In addition to manual and mechanical handling, this section includes policies for industrial trucks, cranes, and rigging.
II. GENERAL POLICY
The handling and storage of materials; the use of powered industrial trucks, cranes, rigging equipment and other power equipment; and the disposal of waste materials shall comply with OSHA (29 CFR 1910.176-184, Subpart N & 29 CFR 1926.250-252, Subpart H Standards) and applicable federal, state, and local laws and regulations. A. Where mechanical handling equipment is used, sufficient safe clearances shall be allowed for aisles, at loading docks, through doorways and wherever turns or passage must be made. Aisles and passageways shall be kept clear and in good repair with no obstruction across or in aisles that could create a hazard. Permanent aisles and passageways shall be appropriately marked.
B. Storage of material shall not create a hazard. Bags, containers, bundles, etc., stored in tiers shall be stacked, blocked, interlocked, and limited in height so that they are stable and secure against sliding and collapsing.
C. Storage areas shall be kept free from accumulation of materials that constitute hazards from tripping, fire, explosion, or pest harborage. Vegetation control will be exercised when necessary.
D. Covers and/or guardrails shall be provided to protect employees from the hazards of open pits, tanks, vats, ditches, etc.
III. MANUAL HANDLING
A. When moving materials manually, employees should attach handles or holders to loads. In addition, employees should always wear appropriate personal protective equipment (PPE) and use proper lifting techniques.
B. To prevent injury from oversize loads, employees should seek help when:
1. a load is so bulky that employees cannot properly grasp or lift it;
2. employees cannot see around or over a load; or
3. employees cannot safely handle a load.
12-2017 Page 81 of 114
C. When manually moving materials, use appropriate PPE. For example:
1. hand and forearm protection, such as gloves, for loads with sharp or rough edges;
2. eye protection; and
3. steel-toed safety shoes or boots.
D. Employees should use blocking materials to manage loads safely. Employees should also be cautious when placing blocks under a raised load to ensure that the load is not released before removing their hands from under the load. Blocking materials and timbers should be large and strong enough to support the load safely. In addition to materials with cracks, employees should not use materials with rounded corners, splintered pieces, or dry rot for blocking.
IV. MECHANICAL HANDLING
A. When moving materials mechanically, employees should avoid overloading equipment by letting the weight, size, and shape of the material being moved dictate the type of equipment used.
B. The equipment-rated capacity must be displayed on each piece of equipment. Employees must not exceed that capacity except for load testing.
C. Although employees may be knowledgeable about powered equipment, they should take precautions when stacking and storing material.
V. STORAGE HAZARDS
A. Stored materials must not create a hazard for employees.
B. Employees should be aware of such factors as the materials’ height and weight, how accessible the stored materials are to the user, and the condition of the containers where the materials are being stored when stacking and piling materials.
C. To prevent creating hazards when storing materials:
1. Keep storage areas free from accumulated materials that cause tripping, fires, or explosions, or that may contribute to the harboring of rats and other pests.
2. Separate non-compatible materials.
12-2017 Page 82 of 114
3. Equip employees who work on hoppers or tanks with lifelines and safety belts.
4. Consider placing bound material on racks, and secure it by stacking, blocking, or interlocking to prevent it from sliding, falling, or collapsing.
VI. STACKING HAZARDS
Stacking materials can be dangerous if employees do not follow safety guidelines. Falling materials and collapsing loads can crush or pin employees.
A. When stacking materials:
1. Stack lumber no more than 16 feet high if it is handled manually, and no more than 20 feet if using a forklift.
2. Remove all nails from used lumber before stacking.
3. Stack and level lumber on solidly supported bracing.
4. Ensure that stacks are stable and self-supporting.
5. Avoid storing pipes and bars in racks that face main aisles to avoid creating a hazard to bystanders when removing supplies.
6. Stack bags and bundles in interlocking rows to keep them secure.
7. Stack bagged materials by stepping back the layers and cross- keying the bags. To remove bags from the stack, start from the top row first. 8. Band boxed materials or secure them with cross-ties or shrink plastic fiber.
9. Stack drums and barrels symmetrically.
10. Block the bottom tiers of drums, barrels, and kegs to keep them from rolling if stored on their sides.
11. Stack and block pipe as well as structural steel, bar stock, and other cylindrical materials to prevent spreading or tilting unless they are in racks.
12. Observe height limitations when stacking materials.
13. Consider the need for availability of the material.
12-2017 Page 83 of 114
VII. POWERED INDUSTRIAL TRUCKS
A. All new powered industrial trucks, except vehicles intended primarily for earth moving or over-the-road hauling, must meet the design and construction requirements for powered industrial trucks established in the American National Standard for Powered Industrial Trucks, Part II, ANSI B56.1-1969. Trucks approved for fire safety must bear a label, or some other identifying mark, indicating acceptance by a nationally recognized testing laboratory.
B. Only trained employees will be permitted to operate Company powered industrial trucks.
C. When operating or maintaining powered industrial trucks:
1. Conduct inspection prior to operating powered industrial truck.
2. Center the load on the forks as close to the mast as possible to minimize the potential for the truck tipping or the load falling.
3. Do not handle loads that are heavier than the rated capacity of the industrial truck.
4. Do not place extra weight on the rear of a counterbalanced forklift to allow an overload.
5. Adjust the load to the lowest position when traveling.
6. Follow the truck manufacturer’s operational requirements.
7. Pile and cross-tier all stacked loads correctly.
8. Properly maintain equipment, including tires.
9. Examine truck for defects before using.
10. Follow safe operating procedures for picking up, moving, putting down and stacking loads.
11. Drive safely, never exceed 5 mph, and slow down in congested or slippery surface areas.
12. Do not engage in stunt driving and horseplay.
13 Remove unsafe or defective trucks from service.
14. Wear seatbelt.
12-2017 Page 84 of 114
15. Make certain that the reverse signal alarm is operational and audible above the surrounding noise level.
16. Equip forklifts with vertical load backrest extensions according to manufacturers’ specifications if the load presents a hazard. 17. Provide auxiliary directional lighting on the truck where general lighting is less than 2 lumens per square foot.
18. Do not place arms and legs between the uprights of the mast or outside the running lines of the truck.
19. Set brakes and put other adequate protection in place to prevent movement of trucks, trailers, or railroad cars when using powered industrial trucks to load or unload materials onto them.
20. Provide sufficient headroom under overhead installations, lights, pipes, and sprinkler systems.
21. Provide occupants on the loading platform with the means to shut off power to the truck whenever a truck is equipped with controls elevatable with the lifting carriage (e.g., man lifts).
22. Secure dock boards, bridge plates, or ramps properly so they won’t move when equipment moves over them.
23. Handle only stable or safely arranged loads.
24. Disconnect batteries before repairing electrical systems on trucks.
25. Use replacement parts on industrial trucks that are equivalent to the original ones.
D. Employees must not make modifications and additions affecting capacity and safe operation of the trucks without the manufacturer’s prior written approval.
E. There are different designations of industrial trucks, and each designation is suitable for use in certain locations and under specific conditions. Employees must operate the appropriate powered industrial trucks in accordance with the approved designation.
VIII. CRANES
A. Only trained employees will be permitted to operate Company cranes.
12-2017 Page 85 of 114
B. When operating a crane:
1. Conduct and document pre-use crane inspection. Critical parts of a crane will be inspected daily for any maladjustment, deterioration, leakage, deformation, or other damage.
2. Check all crane controls for proper operation before use.
3. Inspect wire rope, chains and hook for any damage.
4. Know the weight of the load that the crane is to lift.
5. Do not exceed the crane’s rated capacity load (check the crane’s load chart before lifting).
6. Raise the load a few inches to verify balance and the effectiveness of the brake system.
7. Check all rigging prior to use; do not wrap hoist ropes or chains around the load.
8. Do not move a load over employees.
9. Limit access or barricade accessible areas within the crane’s swing radius.
10. Watch for overhead electrical distribution and transmission lines and maintain a safe working clearance of at least 10 feet from energized electrical lines. Take additional precautions and exercise extra care when operating around power lines.
11. Equip all cranes that have adjustable booms with boom angle indicators.
12. Provide cranes with telescoping booms with some means to determine boom lengths unless the load rating is independent of the boom length.
13. Post load rating charts in the cab of cab-operated cranes. (All cranes do not have uniform capacities for the same boom length and radius in all directions around the chassis of the vehicle.)
14. Safely plan lifts before starting them.
15. Rest outriggers on mobile cranes on firm ground, on timbers, or be sufficiently cribbed to spread the weight of the crane and the load over a large enough area.
12-2017 Page 86 of 114
16. Attach loads to the load hook by slings, fixtures, and other devices that have the capacity to support the load on the hook.
17. Pad sharp edges of loads to prevent cutting slings.
18. Maintain proper sling angles so that slings are not loaded in excess of their capacity.
IX. RIGGING EQUIPMENT
A. General Requirements
1. Rigging equipment for material handling shall be inspected prior to use on each shift and as necessary during its use. Defective rigging equipment shall be removed from service and scrapped.
2. Rigging equipment shall not be loaded in excess of its recommended safe working load.
3. Rigging equipment, when not in use, shall be removed from the immediate work area so as not to present a hazard to employees.
4. Special custom design grabs, hooks, clamps, or other lifting accessories for such units as modular panels, prefabricated structures and similar materials, shall be marked to indicate the safe working loads and shall be proof-tested prior to use to 125% of their rated load.
B. Wire Rope
1. Tables found in 29 CFR 1910.184 and 29 CFR 1926.251 shall be used to determine the safe working loads of various sizes and classifications of improved plow steel wire rope and wire rope slings with various types of terminals.
2. Protruding ends of strands in splices on slings and bridles shall be covered or blunted.
3. Wire rope shall not be secured by knots.
4. The following limitations shall apply to the use of wire rope:
a. An eye splice made in any wire rope shall have, not less than, three full tucks.
b. Except for eye splices in the ends of wires and for endless rope slings, each wire rope used in hoisting or lowering, or
12-2017 Page 87 of 114
in pulling loads, shall consist of one continuous piece without knot or splice.
c. Eyes in wire rope bridles, slings, or bull wires shall not be formed by wire rope clips or knots.
d. Wire rope shall not be used if the rope shows any signs of excessive wear, corrosion, or defect.
e. When U-bolt wire rope clips are used to form eyes, the recommended number and spacing of clips should be followed.
f. When used for eye splices, the U-bolt shall be applied so that the "U" section is in contact with the dead end of the rope.
g. Slings shall not be shortened with knots or bolts or other makeshift devices.
h. Sling legs shall not be kinked.
i. Slings used in a basket hitch shall have the loads balanced to prevent slippage.
j. Slings shall be padded or protected from the sharp edges of their loads.
k. Hands or fingers shall not be placed between the sling and its load while the sling is being tightened around the load.
l. Shock loading is prohibited.
m. A sling shall not be pulled from under a load when the load is resting on the sling.
n. Sling lengths should be limited to manufacturer specifications for the type of sling being used.
o. Wire rope slings of all grades shall be permanently removed from service if they are exposed to temperatures in excess or below manufacturers’ specifications.
p. Welding of end attachments, except covers to thimbles, shall be performed prior to the assembly of the sling.
q. No welded end attachments shall be used unless proof- tested by the manufacturer or equivalent entity at twice their rated capacity prior to initial use. The Company shall
12-2017 Page 88 of 114
retain a certificate of proof-test and make it available for examination.
C. Natural Rope & Synthetic Fiber
1. Tables found in 29 CFR 1910.184 and 29 CFR 1926.251 shall be used to determine the safe working loads of various sizes and classifications of natural rope & synthetic fiber slings with various types of terminals.
2. The following limitations shall apply to the use of natural rope & synthetic fiber:
a. All splices in rope slings provided by the Company shall be made in accordance with the fiber rope manufacturer’s recommendations.
b. In manila rope, eye splices shall contain at least 3 full tucks, and short splices shall contain at least 6 full tucks (3 on each side of the center line of the splice).
c. In laid synthetic fiber rope, eye splices shall contain at least 4 full tucks, and short splices shall contain at least 8 full tucks (4 on each side of the center line of the splice).
d. Strand end tails shall not be trimmed short (flush with the surface of the rope) immediately adjacent to the full tucks.
e. Knots shall not be used in lieu of splices.
f. Natural and synthetic fiber rope slings, except for wet frozen slings, may be used in a temperature range from minus 20° F (-28.88° C) to plus 180° F (82.2° C) without decreasing the working load limit. For operations outside this temperature range and for wet frozen slings, the sling manufacturer's recommendations shall be followed.
g. Spliced fiber rope slings shall not be used unless they have been spliced in accordance with the following minimum requirements and in accordance with any additional recommendations of the manufacturer.
(i) In manila rope, eye splices shall consist of at least 3 full tucks, and short splices shall consist of at least 6 full tucks (3 on each side of the splice center line).
(ii) In synthetic fiber rope, eye splices shall consist of at least 4 full tucks, and short splices shall consist
12-2017 Page 89 of 114
of at least 8 full tucks (4 on each side of the center line).
(iii) Strand end tails shall not be trimmed flush with the surface of the rope immediately adjacent to the full tucks. This applies to all types of fiber rope and both eye and short splices. For fiber rope under 1 inch (2.54 cm) in diameter, the tail shall project at least 6 rope diameters beyond the last full tuck. For fiber rope 1 inch (2.54 cm) in diameter and larger, the tail shall project at least 6 inches (15.24 cm) beyond the last full tuck. Where a projecting tail interferes with the use of the sling, the tail shall be tapered and spliced into the body of the rope using at least 2 additional tucks (which will require a tail length of approximately 6 rope diameters beyond the last full tuck).
(iv) Fiber rope slings shall have a minimum clear length of rope between eye splices equal to 10 times the rope diameter.
(v) Knots shall not be used in lieu of splices.
(vi) Clamps not designed specifically for fiber ropes shall not be used for splicing.
(vii) For all eye splices, the eye shall be of such size to provide an included angle of not greater than 60 degrees at the splice when the eye is placed over the load or support.
h. Fiber rope slings shall not be used if end attachments in contact with the rope have sharp edges or projections.
i. Natural and synthetic fiber rope slings shall be immediately removed from service if any of the following conditions are present:
(i) abnormal wear;
(ii) powdered fiber between strands;
(iii) broken or cut fibers;
(iv) variations in the size or roundness of strands;
(v) discoloration or rotting; and
12-2017 Page 90 of 114
(vi) distortion of hardware in the sling.
D. Synthetic Webbing (nylon, polyester, and polypropylene)
1. Tables found in 29 CFR 1910.184 and 29 CFR 1926.251 shall be used to determine the safe working loads of various sizes and classifications of synthetic webbing slings.
2. The Company shall have each synthetic web sling marked or coded to show: a. name or trademark of manufacturer;
b. rated capacities for the type of hitch; and
c. type of material;
3. Loads shall not exceed rated capacity.
4. Synthetic webbing shall be of uniform thickness and width and selvage edges shall not be split from the webbing's width.
5. Fittings shall be of a minimum breaking strength equal to that of the sling, and free of all sharp edges that could in any way damage the webbing.
6. Stitching shall be the only method used to attach end fittings to webbing and to form eyes. The thread shall be in an even pattern and contain a sufficient number of stitches to develop the full breaking strength of the sling.
7. When synthetic web slings are used, the following precautions shall be taken:
a. Nylon web slings shall not be used where fumes, vapors, sprays, mists of liquids or caustics are present.
b. Polyester and polypropylene web slings shall not be used where fumes, vapors, sprays, mists or liquids of caustics are present.
c. Web slings with aluminum fittings shall not be used where fumes, vapors, sprays, mists or liquids of acids or phenolics are present.
d. Synthetic web slings of polyester and nylon shall not be used at temperatures exceeding 180° F (82.2° C). Polypropylene web slings shall not be used at temperatures exceeding 200° F (93.33° C).
12-2017 Page 91 of 114
e. Synthetic web slings shall be immediately removed from service if any of the following conditions are present:
(i) acid or caustic burns;
(ii) melting or charring of any part of the sling surface;
(iii) snags, punctures, tears or cuts;
(iv) broken or worn stitches; or
(v) distortion of fittings.
E. Shackles & Hooks
1. Tables found in 29 CFR 1910.184 and 29 CFR 1926.251 shall be used to determine the safe working loads of various sizes and classifications of shackles and hooks.
2. The manufacturer's recommendations shall be followed in determining the safe working loads of the various sizes and types of specific and identifiable hooks. All hooks for which no applicable manufacturer's recommendations are available shall be tested to twice the intended safe working load before they are initially put into use. The Company HSE Department shall maintain a record of the dates and results of such tests.
X. MISCELLANEOUS POWERED EQUIPMENT (BACKHOE, DOZER, TRACTOR, ATV, ETC.)
A. Equipment should always be operated in accordance with manufacturer’s specifications.
B. Only trained employees will be permitted to operate Company powered equipment.
C. Equipment should be used for operations that are consistent with the equipment’s design.
XI. DISPOSAL OF WASTE MATERIALS
A. Whenever materials are dropped more than 20 feet to any point lying outside the exterior walls of the building, an enclosed chute of wood, or equivalent material, shall be used. For the purpose of this paragraph, an enclosed chute is a slide, closed in on all sides, through which material is moved from a high place to a lower one.
12-2017 Page 92 of 114
B. When debris is dropped through holes in the floor without the use of chutes, the area onto which the material is dropped shall be completely enclosed with barricades not less than 42 inches high and not less than 6 feet back from the projected edge of the opening above. Signs warning of the hazard of falling materials shall be posted at each level. Removal shall not be permitted in this lower area until debris handling ceases above.
C. All scrap lumber, waste material, and rubbish shall be removed from the immediate work area as the work progresses.
D. Disposal of waste material or debris by burning shall comply with applicable laws and regulations.
E. All solvent waste, oily rags and flammable liquids shall be kept in fire resistant covered containers until removed from site.
F. All wastes shall be disposed in accordance with federal, state, and local laws and regulations.
12-2017 Page 93 of 114
21. NATURALLY OCCURRING RADIOACTIVE MATERIAL (NORM)
I. PURPOSE/SCOPE
This section provides guidance on the identification of naturally occurring radioactive material (NORM) found in the oil and gas industry and on the procedures to be used when the materials are present.
Low level radioactive scale can be produced in the course of some oil and gas operations. This occurs when NORM dissolves into the reservoir water. The production of oil and gas moves NORM to the surface where it can accumulate at low levels in processing and transporting equipment. Some of the locations where NORM is found are as follows: piping, tubing, sludge pits, brine and sand filters, salt water disposal injection wells and equipment, soils at well sites and pipe cleaning and storage yards. NORM deposits can also be found at wellheads, headers, heater treaters, pumps within natural gas processing plants, produced water vessels and other light hydrocarbon processing facilities. NORM may not be present at all locations.
II. GENERAL POLICY
Refer to Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Naturally Occurring Radioactive Material (NORM) Manual (if applicable) for specific requirements regarding operations involving NORM.
A. When the presence of NORM scale is suspected in piping, used tubing, or other equipment, measurement checks will be made to determine the NORM levels. NORM surveys will be conducted by trained employees and/or contractors’ personnel.
B. Vessels containing NORM will be cleaned and pipe scaling operations will be performed only by properly trained employees and/or contractors’ personnel who hold a valid license to perform such operations as required by state law.
C. Employees required to work with equipment containing NORM and NORM materials shall be trained in accordance with Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Naturally Occurring Radioactive Material (NORM) Manual (if applicable).
D. Employees shall strictly follow the requirements set forth in Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Naturally Occurring Radioactive Material (NORM) Manual (if applicable) for working with NORM, including the following precautions:
1. Scale and sands containing NORM will be handled in the wet
12-2017 Page 94 of 114
state to avoid inhalation.
2. Employees shall wear proper protective equipment (PPE).
3. Employees shall avoid direct skin contact with radioactive scale and solids to the extent reasonably possible.
4. Eating, drinking, smoking and chewing will not be allowed in the work area.
5. Employees will thoroughly wash their hands and face following any skin contact that occurs prior to eating, drinking or smoking and at the end of the work day.
6. The number of employees in the work area will be kept to a minimum.
7. Used protective equipment and clothing should be handled in accordance with approved waste disposal procedures outlined in Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Naturally Occurring Radioactive Material (NORM) Manual (if applicable). Contaminated equipment and pipe will be handled according to Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Naturally Occurring Radioactive Material (NORM) Manual (if applicable).
8. Equipment containing NORM shall be labeled according to state and federal requirements.
12-2017 Page 95 of 114
22. TOOL SAFETY
I. GENERAL POLICY
A. All tools and equipment, whether furnished by the Company or employee shall be maintained in a safe condition. Tools and equipment should be inspected prior to use, and any unsafe conditions should be reported immediately to the supervisor.
B. Hand and power tools used shall comply with OSHA Regulations 29 CFR 1910.241 through 29 CFR 1910.244, CFR 1926.300 through 29, CFR 1926.307, and manufacturer’s recommendations.
C. Appropriate personal protective equipment (PPE) such as safety goggles and gloves must be worn to protect against hazards that may be encountered while using tools. Refer to Section 7, Personal Protective Equipment (PPE) and the Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Personal Protective Equipment (PPE) Program in Appendix 1: Programs for specific requirements related to PPE.
II. HAND TOOLS
Hand tools are tools that are powered manually. Hand tools include anything from axes to wrenches. The greatest hazards posed by hand tools result from misuse and improper maintenance.
A. Supervisors shall not issue or permit the use of unsafe hand tools.
B. When using saw blades, knives, or other tools, employees should direct the tools away from aisle areas and away from other employees working in close proximity. Knives and scissors must be sharp; dull tools can cause more hazards than sharp ones. Cracked saw blades must be removed from service.
C. Wrenches must not be used when jaws are sprung to the point slippage occurs. Impact tools such as drift pins, wedges, and chisels must be kept free of mushroomed heads.
D. The wooden handles of tools shall be free of splinters or cracks and shall be kept tight in the tool.
E. Iron or steel hand tools may produce sparks that can be an ignition source around flammable substances. Where this hazard exists, spark- resistant tools made of non-ferrous materials should be used where
12-2017 Page 96 of 114
flammable gases, highly volatile liquids, and other explosive substances are stored or used.
F. Workplace floors shall be kept as clean and dry as possible to prevent accidental slips with or around dangerous hand tools.
III. POWER TOOLS
A. General Precautions
When using power tools, employees should observe the following:
1. Never carry a tool by the cord or hose.
2. Never yank the cord or the hose to disconnect it from the receptacle.
3. Keep cords and hoses away from heat, oil, and sharp edges.
4. Disconnect tools when not using them, before servicing and cleaning them, and when changing accessories such as blades, bits, and cutters.
5. Keep all people not involved with the work at a safe distance from the work area.
6. Secure work with clamps or a vise, freeing both hands to operate the tool.
7. Avoid accidental starting. Do not hold fingers on the switch button while carrying a plugged-in tool.
8. Maintain tools with care; keep them sharp and clean for best performance.
9. Follow instructions in the user’s manual for lubricating and changing accessories.
10. Be sure to keep good footing and maintain good balance when operating power tools.
11. Wear proper apparel for the task. Loose clothing, ties, or jewelry can become caught in moving parts.
12. Remove all damaged portable electric tools from use and tag them, “Do Not Use.”
12-2017 Page 97 of 114
B. Guards
1. The exposed moving parts of power tools will be safeguarded. When powered operated tools are designed to accommodate guards, they shall be equipped with such guards when in use. Belts, gears, shafts, pulleys, sprockets, spindles, drums, flywheels, chains, or other reciprocating, rotating, or moving parts of equipment shall be guarded if such parts are exposed to contact by employees or otherwise create a hazard.
2. Machine guards, as appropriate, must be provided to protect the operator and other employees in the area from hazards such as those created by the point of operation, ingoing nip points, rotating parts, flying chips and sparks.
3. Safety guards must never be removed when a tool is being used.
4. Portable circular saws having a blade greater than 2 inches (5.08 cm) in diameter must be equipped at all times with guards above and below the base plate or shoe. An upper guard must cover the entire blade of the saw. A retractable lower guard must cover the teeth of the saw, except where it contacts the work material. The lower guard must automatically return to the covering position when the tool is withdrawn from the work material.
C. Operating Controls and Switches
1. The following handheld power tools must be equipped with a constant-pressure switch or control that shuts off the power when pressure is released:
a. drills;
b. tappers;
c. fastener drivers;
d. horizontal, vertical, and angle grinders with wheels more than 2 inches (5.08 cm) in diameter;
e. disc sanders with discs greater than 2 inches (5.08 cm); belt sanders;
f. reciprocating saws; saber saws, scroll saws, and jigsaws with blade shanks greater than ¼ inch (0.63 cm) wide; and
g. other similar tools.
12-2017 Page 98 of 114
These tools also may be equipped with a “lock-on” control, if it allows the worker to also shut off the control in a single motion using the same finger or fingers.
2. The following handheld power tools must be equipped with, either, a positive “on-off” control switch, a constant pressure switch, or a “lock-on” control:
a. disc sanders with discs 2 inches (5.08 cm) or less in diameter;
b. grinders with wheels 2 inches (5.08 cm) or less in diameter; and
c. platen sanders, routers, planers, laminate trimmers, nibblers, shears, scroll saws and jigsaws, saber and scroll saws with blade shanks a nominal 1/4 inch (6.35 mm) or less in diameter.
The constant-pressure control switch is the preferred device.
3. All handheld powered circular saws having a blade diameter greater than 2 inches (5.08 cm). Chain saws and percussion tools with no means of holding accessories securely must be equipped with a constant-pressure switch.
D. Electric Tools
The greatest hazards associated with the electrical use of powered tools are the potential for electrical burns and shocks.
The following general practices should be followed when using electric tools:
1. Electric tools shall be properly grounded.
2. Operate electric tools within their design limitations.
3. Wear appropriate PPE such as gloves and footwear when using electric tools.
4. Store electric tools in a dry place when not in use.
5. Do not use electric tools in damp or wet locations unless they are approved for that purpose.
6. Keep work areas well lighted when operating electric tools.
12-2017 Page 99 of 114
7. Keep walkways clear of cords from electric tools to prevent tripping hazards.
Refer to Section 19, Electrical Safety for specific requirements related to electrical safety.
E. Portable Abrasive Wheel Tools
Portable abrasive grinding, cutting, polishing, and wire buffing wheels create safety problems because they may generate flying fragments.
1. Abrasive wheel tools must be equipped with guards that:
a. cover the spindle end, nut, and flange projections;
b. maintain proper alignment with the wheel; and
c. do not exceed the strength of the fastenings.
2. Before an abrasive wheel is mounted, the wheel shall be inspected closely for damage or wear and the spindle speed of the machine shall be checked to be certain that it does not exceed the maximum operating speed marked on the wheel.
3. To prevent an abrasive wheel from cracking, it must fit freely on the spindle. The spindle nut must be tightened enough to hold the wheel in place without distorting the flange.
4. An abrasive wheel may disintegrate or explode during start-up. Employees should allow the tool to come up to operating speed prior to grinding or cutting. Employees should never stand in the plane of rotation of the wheel as it accelerates to full operating speed.
5. Portable grinding tools shall to be equipped with safety guards to protect employees not only from the moving wheel surface, but also from flying fragments in case of wheel breakage. Employees using abrasive wheels shall wear appropriate PPE such as eye and/or face protection.
6. Powered grinders shall be turned off when not in use.
F. Pneumatic Tools
Pneumatic tools are tools that are powered by compressed air. Examples of pneumatic tools are chippers, drills, hammers, and sanders.
12-2017 Page 100 of 114
1. One of the dangers associated with the use of pneumatic tools is the potential for an employee to be hit by one of the tool’s attachments or by a fastener used with the tool.
2. Pneumatic tools shall be securely fastened to the air hose or whip to prevent them from becoming accidentally disconnected. A short wire or positive locking device attaching the air hose to the tool must also be used and will serve as an added safeguard.
3. Air hoses and hose connections used for connecting compressed air to the tools shall be designed for the service and pressure to which they are subjected.
a. If an air hose is more than ½ inch (12.7 mm) in diameter, a safety excess flow valve must be installed at the source of the air supply to reduce pressure in case of hose failure.
b. In general, the same precautions should be taken with an air hose that are recommended for electric cords, because the hose is subject to the same kind of damage or accidental striking and also presents tripping hazards.
c. Air hoses shall not be used for hoisting or lowering tools.
4. When using pneumatic tools, a safety clip or retainer must be installed to prevent attachments such as chisels on a chipping hammer from being ejected during tool operation.
5. Pneumatic tools that shoot nails, rivets, staples, or similar fasteners and operate at pressures more than 100 pounds per square inch (6,890 kPa), must be equipped with a special device to keep fasteners from being ejected, unless the muzzle is pressed against the work surface.
6. Manufacturers’ safe operating pressure for hoses, pipes, valves, filters and other fittings shall not be exceeded.
7. When using pneumatic tools, employees shall wear appropriate PPE.
8. Screens must also be set up to protect nearby workers from being struck by flying fragments around chippers, riveting guns, staplers, or air drills.
9. Compressed air guns should never be pointed toward anyone, and workers should never “dead-end” them against themselves or anyone else.
12-2017 Page 101 of 114
10. A chip guard and appropriate PPE must be used when compressed air is used for cleaning. Compressed air in excess of 30 psi shall not be used for cleaning.
11. Use of heavy jackhammers can cause fatigue and strains. Heavy rubber grips reduce these effects by providing a secure handhold. Workers operating a jackhammer must wear appropriate PPE.
G. Fuel-Powered Tools
Fuel-powered tools are usually operated with gasoline or diesel. Fuel powered tools can create dangerous exhaust fumes and fuel vapors that are a fire/explosion hazard.
1. Fuel shall be handled, transported, and stored only in approved flammable liquid containers, according to proper procedures for flammable liquids.
2. Before refilling a fuel-powered tool tank, employees must shut down the engine and allow it to cool to prevent accidental ignition of hazardous vapors.
3. When a fuel-powered tool is used inside a closed area, effective ventilation and/or proper respirators such as atmosphere- supplying respirators must be utilized to avoid breathing carbon monoxide. Fire extinguishers must also be available in the area.
H. Hydraulic Power Tools
1. The fluid used in hydraulic power tools must be an approved fire resistant fluid and must retain its operating characteristics at the most extreme temperatures to which it will be exposed.
2. The manufacturer’s recommended safe operating pressure for hoses, valves, pipes, filters, and other fittings must not be exceeded.
I. Jacks
Jacks are appliances for lifting and lowering or moving horizontally a load by application of a pushing force. Jacks may be of the following types: lever and ratchet, screw, and hydraulic.
1. The operator shall make sure that the jack has a rating sufficient to lift and sustain the load.
2. The manufacturer’s load limit must be permanently marked in a prominent place on the jack, and the load limit must not be exceeded.
12-2017 Page 102 of 114
3. In the absence of a firm foundation, the base of the jack shall be blocked. If there is a possibility of slippage of the cap, a block shall be placed in between the cap and the load. The operator shall watch the stop indicator which shall be kept clean in order to determine the limit of travel. The indicated limit shall not be overrun. After the load has been raised, it shall be cribbed, blocked or otherwise secured at once.
4. To set up a jack, make certain of the following:
a. The base of the jack rests on a firm, level surface.
b. The jack is correctly centered.
c. The jack head bears against a level surface.
d. The lift force is applied evenly.
4. Jacks shall be properly maintained. All jacks must be lubricated regularly. Hydraulic jacks exposed to freezing temperatures shall be supplied with an adequate antifreeze liquid. Each jack must be inspected according to the following schedule:
a. Jacks used continuously or intermittently at one site shall be inspected at least once every 6 months.
b. Jacks sent out of the shop for special work shall be inspected when sent out and inspected when returned.
c. Jacks subjected to abnormal loads or shock shall be inspected before use and immediately thereafter.
5. Jacks which are out of service shall be tagged accordingly and shall not be used until repairs are made.
12-2017 Page 103 of 114
23. VEHICLE OPERATIONS
I. PURPOSE/SCOPE
This section defines policies and procedures for safe vehicle operation of all Company vehicles. For purposes of this section, Company vehicle means Company-owned, leased or rented vehicles.
II. GENERAL POLICY
Only an employee who has met the following qualifications will be authorized to operate Company vehicles:
A. The employee must have a valid driver’s license for the class and type of vehicle to be operated.
B. The employee must have and maintain an acceptable driving record.
C. The employee must complete any driver training requirement by the Company (if any).
III. DRIVER RESPONSIBILITIES
A. Conduct daily pre-trip checks before using any Company vehicle. The daily pre-trip check will include a review of the following:
1. brakes;
2. headlights;
3. taillights;
4. signal lights;
5. tires;
6. spare tire(s);
7. emergency equipment; and
8. insurance liability card.
B. Check that state registration and safety inspections for Company vehicles are renewed as required by law.
12-2017 Page 104 of 114
C. Report deficiencies in Company vehicles to his or her supervisor.
D. Provide routine vehicle maintenance, upkeep, and repairs.
E. Look around the vehicle for potential hazards before entering the vehicle or putting it in motion.
F. Operate vehicle in accordance with applicable local laws and regulations, including, but not limited to, those pertaining to the use of cellular phones and other devices.
G. Accident reporting procedures are covered under Section 5, Accident/Injury Investigation and Reporting.
IV. VEHICLE MAINTENANCE
A. Company vehicles must be maintained in a proper and safe operating condition. They should be inspected and maintained regularly.
B. Company vehicles that are not in a safe and operable condition will be removed from service and repaired or replaced in kind.
C. All maintenance and repairs will be performed in accordance with manufacturers’ guidelines.
V. SAFETY BELTS AND OTHER SAFETY EQUIPMENT
A. Seat belts must be worn by those driving Company vehicles and by all passengers.
B. All seat belts, alarms and interlock systems must be maintained in working condition.
VI. REQUIRED EMERGENCY EQUIPMENT IN COMPANY VEHICLES
A. ABC fire extinguisher;
B. first aid kit;
C. emergency road side kit; and
D. automobile liability insurance card.
This equipment must be inspected monthly.
12-2017 Page 105 of 114
VII. REQUIRED DOCUMENTATION IN COMPANY VEHICLES
A. valid vehicle registration certificate and current registration decal;
B. current safety inspection decal;
C. license plate; and
D. automobile liability insurance card.
VIII. GENERAL SAFETY
A. Prohibitions while operating a Company vehicle:
1. unsafe or discourteous driving practices such as road hogging, disregarding the rights of pedestrians, violating traffic regulations and deliberate recklessness of any kind;
2. getting in and out of a vehicle while it is in motion;
3. operating any vehicle with a number of occupants that exceeds the manufacturer’s specifications;
4. riding anywhere on the vehicle not designed for passengers;
5. driving a vehicle with the doors open;
6. picking up hitchhikers in Company vehicles;
7. leaving the vehicle unattended with the keys in the ignition;
8. carrying firearms;
9. smoking;
10. smoking while the vehicle is being refueled;
11. driving under the influence of alcohol or drugs; and
12. use of Company vehicle for anything other than its intended purpose.
B. Traffic Regulations
1. Drivers of Company vehicles must adhere to all applicable traffic regulations.
2. Company vehicles must be operated within the legal posted speed
12-2017 Page 106 of 114
or reduced vehicle speed when confronted with adverse road and weather conditions. It is good practice for drivers to use their headlights at all times. The headlights will alert other drivers to their presence.
C. Avoiding Fatigue
To enhance alertness and safety while driving, drivers should avoid driving after insufficient sleep.
D. Avoiding Distractions
Drivers should make every effort to avoid distractions and maintain control of the vehicle.
E. Cell Phone or Communications Radio Use
1. Drivers must abide by local laws and regulations regarding cell phone use while driving.
2. If a critical need arises requiring a driver to use a cell phone or communications radio, as a first and preferred alternative, pull the vehicle over in a safe manner and place in park before using the cell phone or communications radio. Otherwise, hands free devices or speakerphones shall be used.
3. Texting or emailing is prohibited while driving.
4. Always use extreme caution when using a cell phone or communications radio while driving.
5. If adverse weather conditions exist, such as rain or fog, drivers should refrain from using a cell phone or communications radio, including hands free devices or speakerphones.
F. Refueling
When refueling a vehicle, drivers should:
1. always shut off the engine before dispensing fuel;
2. not smoke;
3. avoid reentering and exiting the vehicle while dispensing fuel as this could create a static spark; and
4. turn off any cell phone or leave it inside the vehicle.
12-2017 Page 107 of 114
G. Parking
1. It is the preferred practice to park vehicles so that, when leaving, the first move is forward. If parking conditions prevent this (e.g. confined maneuvering space or other obstructions) and drivers must back out of a parking space, drivers should carefully check that no other vehicles are approaching or backing into that lane at the same time.
2. If parking on a slope, turn front wheels towards the curb and use the parking brake.
3. Do not park in aisles, doorways, exit or escape routes, or anywhere that blocks visibility or access to safety equipment.
H. Using a Bumper Jack
1. When using a bumper jack and changing a tire, follow the manufacturer’s instructions. These are usually posted on the underside of the trunk lid or in the owner’s manual.
2. Set the parking brake and engage the transmission before raising the car.
3. Keep hands, feet and body in the clear as much as possible, in case the jack fails. Never crawl under a vehicle raised by a bumper jack or any other support that could fail.
I. Transporting Items:
1. Do not carry loose items, such as hard hats and books on the dash or rear tray of the back window in a passenger vehicle.
2. Heavy tools should not be transported in the passenger compartment of vehicles.
3. Tools and equipment should not be carried loose in the back of a truck. Tie down these items or place them in a properly installed tool box
4. Secure trailers properly by using the proper rated receiver and hitch for the payload. Verify that the trailer lights and brakes are working before using the trailer. Trailer safety chains should be attached to the vehicle being towed at the designated attachment points. Safety chains should be crisscrossed to form an “X” under the trailer tongue.
5. Do not overload vehicles. Keep payloads at or under the manufacturer’s Gross Vehicle Weight Rating (GVWR).
12-2017 Page 108 of 114
6. Flammable liquids must be transported in an explosion-and spill- proof container.
7. Do not carry hazardous or dangerous materials in the passenger areas of Company vehicles or in the trunk of any passenger car.
8. Comply with all applicable DOT HAZMAT transportation requirements.
9. Loads should not be off balance. If a load is too high or off balance, the load should be split or rearranged.
J. Night Driving
Night driving presents various hazards, including:
1. reduced visibility;
2. reduced peripheral vision;
3. impaired ability to judge distance, movement and color; and
4. drowsiness.
To reduce the hazards presented by night driving, drivers should:
1. turn headlights on at twilight;
2. slow down;
3. maintain a safe distance between their vehicle and the vehicle in front of them;
4. look forward and slightly to the right, not directly at the high-beams of an approaching vehicle; and
5. put their rearview mirror in the night position to reduce glare.
K. Driving in the Rain
When driving in the rain, be aware of hazardous conditions, which could cause the vehicle to skid. To avoid skidding, drivers should:
1. accelerate gently;
2. brake gently;
3. corner gently;
12-2017 Page 109 of 114
4. check brakes often;
5. use low headlight beams;
6. check tire treads often;
7. drive at lower speeds;
8. double normal braking distance;
9. pull over to the side or exit the highway during heavy downpours and engage hazard lights; and
10. look out for other dangers associated with heavy rain (e.g., flash flooding.
L. Driving in Foggy Conditions
When driving in foggy conditions, watch for reduced visibility and slippery and wet road conditions. To reduce the hazards associated with foggy conditions, drivers should:
1. gradually decrease speed;
2. use only low-beam headlights;
3. signal for turns well in advance;
4. brake early to warn other drivers; and
5. never try to pass other vehicles on two-way roads.
M. Other Hazards and Safe Practices
1. Drivers should be cautious when driving near large trucks and should follow these precautions:
a. avoid tailgating and driving alongside a large truck for extended periods;
b. never pull out in front of a large truck or cut off a large truck; and
c. do not drive in a large truck’s blind spots or too closely in front of the truck.
12-2017 Page 110 of 114
2. To avoid hazards at intersections, drivers should:
a. scan the intersection before they reach it, looking for traffic control devices, pedestrians, construction, other drivers about to change direction, or any other hazards;
b. maintain a safe distance between you and the car stopped ahead of you to avoid involving additional vehicles or pedestrians if you are rear-ended and to allow maneuvering if a car ahead of you should stall;
c. wait 2 or 3 seconds before entering the intersection after the light turns green;
d. be cautious for vehicles that may be running the traffic signal, before entering the intersection;
e. never assume pedestrians will see their vehicle or yield to them before entering the crosswalk; and
f. use turn signals when making turns or changing lanes.
3. In the event of a breakdown, drivers should:
a. pull to the side of the road and onto the shoulder;
b. turn on the vehicle’s hazard warning lights; and
c. use the cell phone or communications radio, if available, to summon help.
4. When encountering an accident scene, drivers should continue moving and:
a. remain alert and briefly assess the accident scene;
b. resist the urge to stare (rubberneck); and
c. begin braking early to warn other drivers.
5. Drivers should yield to emergency vehicles.
6. Drivers should pay attention to road signs warning them to slow down or change lanes in construction zones.
12-2017 Page 111 of 114
7. To avoid animals that have wandered onto the roadway, drivers should:
a. stay alert, especially during evening and early morning hours and where animal crossing signs are posted;
b. never assume animals will get off the road to avoid being hit;
c. slow down when animals are wandering close to the roadway; and
d. avoid causing an accident by slamming on the brakes.
8. Drivers should sound the horn when coming around blind spots or at any time when needed to warn or alert other drivers or employees.
9. Drivers should always look in the direction of movement before moving and should continually scan the path of the travel when in motion.
10. Drivers should maintain a 3-second rule when following other vehicles.
11. Drivers should operate Company vehicles in a responsible manner and will not engage in horseplay or risk-taking activities, such as running red lights.
12. Drivers should travel in a straight line up or down hills and grades. Drivers should not turn around on hills or grades as it greatly increases the risk of vehicles tipping or rolling over.
13. Drivers should use signals to indicate when turning or changing lanes.
IX. AUTOMOBILE ACCIDENTS
In the event of an accident, the following guidelines will apply:
A. STOP immediately after an accident has occurred.
B. Immediately notify local police department and supervisor. Call for emergency medical assistance if necessary.
C. Set out emergency reflectors or flares, if available, to protect yourself and other individuals at the scene.
12-2017 Page 112 of 114
D. Obtain the following information at the accident scene:
1. name(s), addresses and phone numbers of persons involved, as well as any witnesses;
2. drivers license numbers;
3. vehicle license plates;
4. insurance information; and
5. name(s) and badge numbers of law enforcement agencies and officials responding.
E. As soon as possible, complete the Perdure TRP Driver’s Vehicle Accident Report, a copy of which is located in Appendix 2: Forms.
F. Do not discuss the accident with anyone other than the police, supervisor/manager, Senior Safety Officer or designee, Human Resources and Company legal counsel.
12-2017 Page 113 of 114
24. EXPOSURE CONTROL – BLOODBORNE PATHOGENS
OSHA requires each employer having employees with occupational exposure to establish a written exposure control plan in accordance with 29 CFR 1910.1030. The Company has evaluated its operations and determined that its employees do not have occupational exposure to blood or other potentially infectious materials as defined by OSHA. Company employees are not emergency responders, nor do they work in healthcare or in a laboratory where bodily fluids are routinely handled, disposed of, or processed. Company employees may be potentially exposed in rendering first aid to an injured co-worker. However, no employee is required as part of his or her job duties to render first aid to an injured co-worker and would be expected to render first aid only voluntarily as a “Good Samaritan.”
12-2017 Page 114 of 114
APPENDIX: 1 PROGRAMS
3. ACCIDENT AND INJURY REPORTING 4. CONFINED SPACE PROGRAM 5. DRUG & ALCOHOL TESTING POLICY 6. EMERGENCY RESPONSE TEMPLATE 7. HAZCOM PROGRAM 8. HEARING CONSERVATION PROGRAM 9. HOT WORK POLICY FOR GFF PERDURE TABULA RASA 10. HYDROGEN SULFIDE (H2S) SAFETY POLICY 11. JSA SAFE WORK PERMIT 12. LOCKOUT-TAGOUT (LOTO) PROGRAM 13. PPE PROGRAM 14. RESPIRATORY PROTECTION PROGRAM 15. SPCC ANNUAL TRAINING 16. SSE PROGRAM
It is imperative that all accidents, injuries, spills and vehicle accidents be reported to applicable Operations managers in the Allen office immediately upon their occurrence, regardless of the time of occurrence. Additionally, I as HSE Director shall be notified immediately thereafter following report to management, regardless of the time of day or night. This necessarily means that any employee experiencing or witnessing any of these incidents shall immediately notify their supervisor.
I. GENERAL POLICY
A. Employees shall immediately report all work-related accidents involving injuries, fatalities and/or damage to Company equipment, property, or material to their supervisor.
B. Employees shall report any work-related “near miss” to their supervisor as soon as possible. A “near miss” is an incident caused by a faulty process, human error or mechanical failure that could have resulted in an injury, fatality, property damage, a release, or a fire/explosion.
C. Any work-related fatality or accident requiring the hospitalization of 3 or more employees must be orally reported to OSHA within 8 hours of learning of the incident. (This report to OSHA will be made by the HSE Director or his designee.)
III. ACCIDENT / INJURY REPORTING A. Incident Report
1. All work-related accidents involving injuries, illnesses, and fatalities and/or damage to Company equipment, property, or material shall be recorded on the Incident Report in accordance with the Company’s third party providers requirements.
2. The Incident Report shall be completed within 24 hours of any such incident and sent to the Allen Corporate Office. (Please email or scan to the HSE Director within the 24 hours, regardless of the day of week.)
B. Automobile Accident Report
a. Any accidents involving a Company vehicle shall be reported to the Company Senior Safety Officer (HSE Director) as soon as possible. The Senior Safety Officer will be responsible for contacting other applicable parties.
b. The Automobile Accident Report will be completed in its entirety and forwarded to the Operations Department (Health, Safety and Environmental Director) or their designee within 24 hours after the accident.
The Perdure/Tabula Rasa Initial Incident Report (for all injuries, spills, property damage and near-miss incidents, etc.) and the Driver’s Vehicle Accident Report (for all single vehicle accidents and collisions) forms can be found in the Appendix . Damage to parked vehicles or from road hazards that do not result in vehicle accidents is to be reported on the Initial Incident Report form.
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
1) PURPOSE AND SCOPE
This program establishes the safety requirements for safely entering Confined Spaces and preventing accidents involving Confined Spaces.
Reference: OSHA Standard 29 CFR 1910.146
2) POLICY
All Confined Space entries shall be made by Contractors in accordance with these policies and procedures. Under no circumstance are Confined Spaces to be entered without following these policies and procedures. Employees are prohibited from conducting confined space entry. Confined space entry is to be done exclusively by qualified, trained contractors under MSA with Tabula Rasa Energy or Perdure Petroleum LLC.
a) Identifying Confined Spaces:
i) Recognition is an important aspect of making a safe entry into a Confined Space. Not all Confined Spaces will be considered Permit-Required Confined Spaces (referred to herein as “Permit Spaces”) and being able to identify the difference between the two is important. To clarify what constitutes a Confined Space, the following definition will be used:
(1) It is large enough or so configured that an employee can bodily enter and perform the assigned work;
(2) It has limited or restricted means for entry or exit. Confined Space openings are limited primarily by size and location. Openings may be small in size and may be difficult to move through easily. However, in some cases openings may be very large, for example, open-topped spaces such as pits or excavations. Entrance and exit may be required from top, bottom, or side. In some cases, having to access the work area by a fixed ladder may constitute limited or restricted entry or exit. Size or location may make rescue efforts difficult; and
(3) It is not designed for continuous employee occupancy. Most Confined Spaces are not designed for employees to enter and work on a routine basis. They may be designed to store a product, enclose materials and processes, or transport products or substances. Because they are not designed for continuous occupancy, frequently they will not have good ventilation or lighting. Therefore, occasional employee entry for inspection, maintenance, repair, cleanup, or similar tasks can be difficult and dangerous. The danger associated with entry may come from chemical or physical hazards within the space.
ii) A Non-Permit Confined Space is a Confined Space that does not contain, nor has the potential to contain, any hazard capable of causing death or serious
1 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
physical harm (with respect to hazards). Examples of Non-Permit Confined Spaces might include the interiors of HVAC units, attics, walk-in freezers or refrigerators, and some building crawl spaces.
b) Identifying Permit-Required Confined Spaces (or “Permit Spaces”):
i) A Permit Space is a Confined Space that is potentially hazardous. A Permit Space has one or more of the following characteristics:
(1) It contains, or has a potential to contain, a Hazardous Atmosphere.
(2) It contains a material that has the potential for engulfing an entrant.
(3) It has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly-converging walls or by a floor that slopes downward and tapers to a smaller cross-section.
(4) It contains any other recognized serious safety or health hazard. Examples of serious safety or health hazards might include, but are not limited to:
(a) fall hazards;
(b) unguarded machinery;
(c) extreme heat or cold;
(d) steam pipes or chemical lines;
(e) hazardous noise levels;
(f) electrical hazards;
(g) presence of asbestos; or
(h) potentially hazardous levels of dust.
ii) Liquid or dry storage tanks that can be entered (portable, fixed), pipelines, any process vessel, or any space that must be entered through a manhole, hatch or cover shall be considered a Permit Space.
c) Identifying Hazards Within a Permit Space:
i) Once a Confined Space has been identified as Permit Space, the hazards that may be present within the Permit Space must be identified before entry. Permit Space hazards can be grouped into the following categories:
(1) Oxygen-Deficient Atmospheres:
2 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
(a) The normal atmosphere is composed of approximately 21% oxygen and 79% nitrogen. An atmosphere containing less than 19.5% oxygen shall be considered oxygen deficient. The oxygen level inside a Permit Space may be decreased as the result of either consumption or displacement.
(b) There are a number of processes that consume oxygen in a Permit Space. Oxygen is consumed during combustion of flammable materials, as in welding, cutting, or brazing. Carbon dioxide can displace oxygen. A more subtle consumption of oxygen occurs during bacterial action, as in the fermentation process. Oxygen can also be consumed during chemical reactions such as in the formation of rust on the exposed surfaces of a Permit Space. The number of people working in a Permit Space and the amount of physical activity can also influence oxygen consumption. Oxygen levels can also be reduced as the result of oxygen displacement by other gases.
(2) Flammable Atmospheres:
(a) Flammable Atmospheres are generally the result of flammable gases, vapors, dust mixed in certain concentrations with air or an Oxygen- Enriched Atmosphere.
(b) Oxygen-Enriched Atmospheres are those atmospheres that contain an oxygen concentration greater than 23.5%. Oxygen-Enriched Atmospheres will cause flammable materials such as clothing and hair to burn violently when ignited.
(c) Combustible gases or vapors can accumulate within a Permit Space when there is inadequate ventilation. Gases that are heavier than air will accumulate in the lower levels of a Permit Space.
(d) The work being conducted in a Permit Space can generate a Flammable Atmosphere. Work such as spray-painting, coating, or the use of flammable solvents for cleaning can result in the formation of an explosive atmosphere. Welding or cutting with oxyacetylene equipment can also be the cause of an explosion in a Permit Space and shall not be allowed without a Hot Work Permit. Oxygen and acetylene hoses may have small leaks in them that could generate an explosive atmosphere and, therefore, should be removed when not in use. The atmosphere shall be tested continuously while any Hot Work is being conducted within the Permit Space.
(3) Toxic Atmospheres:
Toxic atmospheres may be present within a Permit Space as the result of one or more of the following:
(a) When a product is stored in a Permit Space, the product can be absorbed by the walls and give off toxic vapors when removed or
3 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
when cleaning the residual material. The product can also produce toxic vapors that will remain in the atmosphere due to poor ventilation.
(b) Toxic atmospheres can be generated as the result of work being conducted inside the Permit Space. Examples of such work include welding or brazing with metals capable of producing toxic vapors, painting, scraping, sanding, etc. Many of the solvents used for cleaning and/or degreasing produce highly toxic vapors.
(c) Toxic fumes produced by processes near the Permit Space may enter and accumulate in the Permit Space. For example, if the Permit Space is lower than the adjacent area and the toxic fume is heavier than air, the toxic fume may settle into the Permit Space.
(4) Mechanical and Physical Hazards:
(a) Problems such as rotating or moving mechanical parts or energy sources can create hazards within a Permit Space. All rotating or moving equipment such as pumps, process lines, electrical sources, etc., within a Permit Space must be identified. Falls are another hazard when employees are entering vertically or performing work above 4 feet.
(b) Physical factors such as heat, cold, noise, vibration, and fatigue can contribute to accidents. These factors must be evaluated for all Permit Spaces.
(c) Excavations could present the possibility of engulfment. Employees shall be protected from cave-ins by sloping, benching, or shoring systems when the depth of the excavation is more than 4 feet. In some circumstances, air monitoring may also be required. Excavation, trenching, and shoring operations will be conducted in accordance with 29 CFR 1926.650, 29 CFR 1926.651, and 29 CFR 1926. 652.
d) Required Authorization (preventing unauthorized entry):
i) Only Authorized Entrants may enter a Permit Space. Authorized Entrants are employees who are approved or assigned by the site supervisor in charge of the entry to enter the Permit Space and who must also be trained to the appropriate level for the purpose of entry.
ii) Authorized Entrants must obtain an Entry Permit before entering a Permit Space. Entry is strictly forbidden for those persons without an Entry Permit.
iii) All Authorized Entrants shall be listed on the entry log/permit.
4 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
e) Permit System:
i) When a Permit Space must be entered, an Entry Permit shall be completed and authorized by a designated representative prior to entry of the Permit Space. This permit shall serve as certification that the space is safe for entry. See “Documentation and Recordkeeping” for Entry Permit requirements.
ii) An Entry Permit shall not be authorized, nor entry made, until all conditions of the permit have been safely met and maintained throughout entry.
iii) The duration of the Entry Permit may not exceed the time requirement to complete the assigned task or job identified on the permit. The maximum duration for an Entry Permit is one 12-hour work shift. When the Permit Space entry involves work, which will exceed one 12-hour work shift, a new Entry Permit shall be issued for each shift.
iv) The Entry Supervisor shall terminate the entry and cancel the Entry Permit when the entry operations covered by the Entry Permit have been completed or when a condition that is not allowed under the Entry Permit arises in or near the Permit Space.
v) Each cancelled Entry Permit shall be retained for at least one year to facilitate review of the Permit Space program.
f) Air Monitoring:
i) Air monitoring shall be performed in accordance with the “Atmospheric Testing Procedures” below.
ii) Air monitoring shall be documented on the Entry Permit by the Entry Supervisor.
iii) Air monitoring shall be done in accordance with the following:
(1) Before entry is first allowed, the atmosphere must be safe and not hazardous in accordance with published OSHA standards (see “Procedures” below);
(2) Air monitoring shall be done periodically inside the Permit Space to verify conditions inside the Permit Space remain safe and not at hazardous levels; and
(3) If all Authorized Entrants exit the Permit Space, the air must be monitored again before the Authorized Entrants are allowed to enter again.
iv) An entry log shall be maintained near the entryway of the Permit Space. See “Documentation and Recordkeeping” for entry log requirements.
5 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
g) Equipment/Materials:
i) The Company shall provide all equipment required for safe Permit Space entry at no cost to the employees. Equipment includes, but is not limited to:
(1) testing and monitoring equipment;
(2) ventilation equipment (air horns, copus blowers);
(3) communications equipment;
(4) lighting equipment;
(5) equipment needed for safe ingress and egress;
(6) rescue and emergency equipment;
(7) barriers and shields, if required;
(8) safety equipment (i.e., tripod, full body harness, etc.); or
(9) proper Personal Protective Equipment (PPE), including respiratory protection if required and proper tools to do the work. Note: Authorized Entrants should not be assigned tasks requiring use of respirators unless it has been determined that they are physically able to perform the work and use the equipment. See Tabula Rasa Energy, LLC Respiratory Protection Program for details of medical evaluations.
ii) All equipment to be used in a Permit Space shall be explosion proof (Class I, Division I) or intrinsically safe.
iii) All air monitoring equipment shall be calibrated and maintained in accordance with manufacturer’s instruction.
h) Identify all Permit Spaces:
i) All Permit Spaces located within a facility shall be identified and marked in accordance with “Marking” below.
ii) Permit Spaces shall include all spaces as per definition, regardless if Permit Space is temporary or permanent or if a contractor brings space onsite.
i) Marking:
i) All spaces identified as Permit Spaces shall be marked with a sign stating “DANGER – PERMIT SPACE, DO NOT ENTER” or similar danger verbiage.
6 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
ii) Required signs shall be placed in the immediate area of each possible entry access point into a Permit Space, so as to be readable to persons who could enter the space.
iii) All signs shall remain in legible condition at all times. They shall be kept clean and shall be replaced when they become faded or otherwise illegible.
j) Contractors:
i) Whenever contractors are to be engaged in activities covered by the scope and application of this policy and procedure, the Company shall inform the contractors of the Confined Space Entry Program adopted by the Company. The contractor’s confined space entry program shall, at a minimum, meet the requirements adopted by the Company.
ii) When the Company’s employees and the contractor’s personnel will be working in or near Permit Spaces simultaneously, the Company and contractor shall coordinate entry operations with each other to prevent the employees of one from endangering the employees of the other.
k) Documentation and Recordkeeping:
i) The Company will provide all affected employees a copy of the Confined Space Entry Program.
ii) Entry Permit:
The Entry Permit shall be made available at the time of entry to all Authorized Entrants or their authorized representatives by either posting it at the entryway into the Permit Space or by placing it in immediate area of entryway. Authorized Entrants must be able to confirm that pre-entry preparations have been completed. The Entry Permit shall identify:
(1) the Permit Space to be entered ;
(2) the purpose of the entry;
(3) the date and authorized duration of the Entry Permit;
(4) the Authorized Entrants within the Permit Space, by name or by such other means as will enable the Attendant to determine quickly and accurately, for the duration of the permit, which Authorized Entrants are inside the Permit Space;
(5) the employee, by name, currently serving as Attendant;
7 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
(6) the employee, by name, currently serving as Entry Supervisor, with a space for the signature or initials of the Entry Supervisor who originally authorized entry;
(7) the hazards of the Permit Space to be entered;
(8) the measures used to isolate the Permit Space and to eliminate or control Permit Space hazards before entry;
(9) the acceptable entry conditions;
(10) the results of initial and periodic air monitoring tests performed under this program, accompanied by the names or initials of the testers and by an indication of when the tests were performed;
(11) the rescue and emergency services that can be summoned and the means for summoning those services;
(12) the communication procedures used by Authorized Entrants and Attendant to maintain contact during the entry;
(13) equipment, such as PPE, testing equipment, communications equipment, alarm systems, and rescue equipment, to be provided for compliance with this program;
(14) any other information necessary to ensure employee safety; and
(15) any additional permits, such as for Hot Work, that have been issued to authorize work in the Permit Space.
iii) Entry log:
An entry log shall be maintained listing Authorized Entrants in a Permit Space at any given time. At any given time, the list must accurately reflect who is currently in the Permit Space and who has been in the Permit Space, including the times (in/out) of those entries.
iv) Training certifications:
(1) The certification shall contain each employee’s name, dates of training, and instructor’s signature.
(2) The certification shall be available for inspection by employees and their authorized representatives.
(3) Documentation of training will be maintained by the Company.
8 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
l) Training and Communication:
i) Training shall be provided so that all employees whose work is regulated by this program and OSHA regulations acquire the understanding, knowledge and skills necessary for the safe performance of the duties assigned under this program. Training may be provided by computer based training (CBT).
ii) Training shall be provided to each affected employee:
(1) before the employee is first assigned duties under this section;
(2) before there is a change in assigned duties;
(3) whenever there is a change in Permit Space operations that presents a hazard about which an employee has not previously been trained; or
(4) whenever the Company has reason to believe either that there are deviations from the Permit Space entry procedures required or that there are inadequacies in the employee's knowledge or use of these procedures.
iii) The training shall establish employee proficiency in the duties required by this program and OSHA regulations and shall introduce new or revised procedures, as necessary, for compliance with this program.
iv) The Company shall certify that the training required by this program and OSHA regulations has been accomplished. See “Documentation and Recordkeeping” for further details.
v) Further, each employee affected by this program shall be trained to the appropriate level (Entry Supervisor, Attendant or Authorized Entrant).
vi) Retraining shall be provided to each affected employee:
(1) whenever there is a change in his or her job assignment;
(2) whenever there is a change in machines, equipment or processes that presents a new hazard; or
(3) whenever there is a change in the energy control procedure.
Additional retraining shall also be conducted whenever a periodic inspection reveals, or whenever the Company has reason to believe, that there are deviations from, or inadequacies in the employee’s knowledge or use of the energy control procedures.
9 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
m) Review of the Confined Space Entry Program:
The Company shall review the Confined Space Entry Program by reviewing the completed Entry Permits within one year after each entry. The Company shall review the Confined Space Entry Program to determine its effectiveness and revise, as needed, to protect employees participating in entry operations from Permit Space hazards. This review may be in the form of a single annual review covering all entries performed during a 12-month period. If no entry is performed during a 12-month period, no review is necessary.
3) PROCEDURES
a) Planning the Entry:
The first step towards conducting a safe Permit Space entry is to plan the entry. This will allow for the identification of all hazards, and for the determination of all equipment necessary, to complete the project.
i) Gather general data:
(1) Identify the Permit Space. Give the name or location of the Permit Space.
(2) Give the reason for entering the Permit Space. Be specific. Also, identify if Hot Work will be done.
(3) Identify the contents of the Permit Space. This refers to any chemicals or other materials and energy that are usually present in the Permit Space.
ii) Identifying the hazards:
Atmospheric testing shall be conducted prior to allowing anyone to enter the Permit Spaces. It is recommended that the Entry Supervisor conduct these tests; however, the Entry Supervisor can authorize any employee certified in Confined Space entry to conduct these tests.
(1) The Entry Supervisor will determine the oxygen content and record this on the Entry Permit.
(2) The Entry Supervisor will determine flammable gas content and record this on the Entry Permit.
(3) The Entry Supervisor will determine levels of H2S and Carbon Monoxide and record this on the Entry Permit.
(4) If a toxic substance is determined to be in the Permit Space during testing by the Entry Supervisor, the HSE representative shall be contacted to
10 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
assist in obtaining a Material Safety Data Sheet (MSDS) or other chemical information to determine what type of PPE is required, the potential health effects, the Permissible Exposure Limits, and any other information needed to safely conduct the work.
(5) Entry Supervisors will determine mechanical and physical hazards. They should list all items and energy that will require lockout/tagout, blanking and bleeding, disconnecting, or securing. Physical hazards should also be listed.
(6) Ventilation of the Permit Space: Indicate whether mechanical or natural ventilation will be used. Describe the procedures to be used. If mechanical ventilation is to be used, the exhaust must be pointed away from employees or ignition sources. Also, mechanical ventilators shall be bonded to the Permit Space.
iii) Isolating the Permit Space:
(1) Describe the procedures for disconnecting equipment or lockout and tagout (LOTO). All mechanical, electrical, or heat-producing equipment should be disconnected or locked and tagged out. This would also include any pumps that pull fluid from, or pump fluid into, the Permit Space.
(2) Refer to the Tabula Rasa Energy, LLC Lockout/Tagout (LOTO) Program for detailed requirements related to LOTO.
iv) Purging/cleaning the Permit Space:
(1) Indicate if the Permit Space will be purged. Purging with inert gas is not recommended. If the Permit Space must be purged, describe the procedures.
(2) Indicate the type of cleaning methods to be used. If chemical cleaners are to be used, name the type and describe the procedures. The MSDS for the chemical should be consulted prior to use. When introducing a chemical into a Permit Space, the compatibility of that chemical with the contents of the Permit Space must be checked. If in doubt, consult the HSE representative. If steam is to be used, the hose should be bonded to the Confined Space.
(3) Placement of warning signs:
Indicate if warning signs or barriers will be needed to prevent unauthorized entry or to protect workers from external hazards. If the Permit Space will be left open and unattended for any length of time, warning signs and barriers such as barricades and/or caution tape will be required.
11 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
(4) Identifying all employees: List all employees that will be required to prepare the Permit Space and complete the work inside the Permit Space.
(5) Identifying necessary equipment:
List all equipment that will be necessary to complete the project.
b) Conducting Pre-Entry Instruction:
Once the entry has been planned, the Entry Supervisor must provide instructions for all employees who will be involved in the entry no earlier than one day before entry is to be made.
The following information shall be communicated:
i) Identify the Permit Space and reason(s) for entry.
ii) Identify the work detail:
(1) Assign each employee the job(s) he or she is to perform in the entry project (Authorized Entrant, Attendant, etc.);
(2) If an employee is required to use a piece of equipment, be sure that he or she is capable of using the equipment properly; and
(3) Inform Authorized Entrants that they are not to enter the Permit Space unless the Attendant is present at the site;
iii) Inform affected employees of suspected hazards:
(1) Identify any access or exit problems;
(2) Identify equipment that must be locked out or tagged out;
(3) Identify the contents of the Permit Space; and
(4) Identify potential toxic atmospheric levels:
(a) Inform affected employees of all atmospheric levels that must be maintained before entering and while working in the Permit Space;
(b) Inform affected employees of the maximum Permissible Exposure Level (PEL) that can exist within the Permit Space if respiratory protection is not going to be used;
(c) Inform affected employees of the potential health effects of exposure to the toxic atmosphere or substance; and
12 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
(d) Inform affected employees of the signs and symptoms of exposure to the toxic fume.
iv) Inform affected employees of the isolation procedures:
(1) Identify employees responsible for the isolation of equipment; and
(2) Identify employees responsible for performing this function of the methods to be used (i.e. LOTO, block and bleed, disconnect, etc.).
v) Inform all employees responsible for performing purging and/or ventilation procedures of the methods to be used.
vi) Identify all equipment needed:
(1) Inform employees involved in the project of all equipment that will be necessary to complete the project; and
(2) Make sure that all employees are capable of using their assigned equipment properly.
vii) Determine necessary PPE:
(1) Inform employees of all PPE that must be used to ensure their safety and
(2) Make sure that all employees required to use PPE are trained in the proper use of the equipment.
viii) Establish Communication.
(1) Inform all Authorized Entrants that they are required to maintain communication with the Attendant;
(2) Inform Attendant that he or she must maintain constant contact with all Authorized Entrants and
(3) Inform Attendant and Authorized Entrants of the type of communication to be used.
ix) Protection from external hazards and risks:
Inform employees where signs and barriers will be placed to prevent unauthorized entry and protect entrants from external hazards.
x) Emergency and rescue procedures.
(1) Inform the designated Attendant of the rescue procedures to be followed. See “Emergency and Rescue Procedures” below; and
13 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
(2) Inform the Attendant that he or she must not enter the Permit Space under any circumstances.
xi) Place the Permit Space back in service:
Inform employees of the steps to be taken to place the Permit Space back into service.
c) Preparing the Permit Space for Entry:
Once the entry has been planned, and employees have been instructed, the next step is to prepare the Permit Required Confined Space for entry.
The following steps are to be followed when preparing the Permit Space for entry:
i) Place warning signs or barriers around the Permit Space to prevent unauthorized entry as necessary;
ii) Place all tools, safety equipment, monitoring equipment, etc., near the Permit Space and
iii) Isolate all mechanical and/or electrical hazards as necessary. Refer to Tabula Rasa Energy, LLC Lockout/Tagout (LOTO) Program for detailed requirements related to LOTO.
iv) Purge/ventilate the Permit Space as necessary.
v) Test the atmosphere using an appropriate gas monitor:
(1) If oxygen content is less than 19.5% or greater than 23.5%, perform additional ventilation. After additional ventilation is complete, shut off the ventilation and re-test the oxygen concentration; and
(2) If oxygen content is between 19.5% and 23.5%, continue entry preparation.
vi) Test for flammable gases:
(1) If the meter reading is less than 10% of the Lower Explosive Limit (LEL), continue entry preparations; and
(2) If the meter reading is above 10% of the LEL, continue ventilation of the Confined Space. After additional ventilation is complete, shut off the ventilation and re-test the flammable (LEL) concentration.
vii) Test for toxics:
If a toxic atmosphere is present, no person should be permitted to enter the Permit Space at a level exceeding the Permissible Exposure Limit without
14 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
proper PPE. The HSE representative should be called to assist in identifying proper precautions and the protective measures to be taken.
d) Utilizing Safety Equipment:
To facilitate non-entry rescue, retrieval systems shall be used whenever Authorized Entrants enter a Permit Space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. Retrieval systems shall meet the following requirements:
i) Each Authorized Entrant shall use a chest or full body harness, with a retrieval line attached at the center of the entrant’s back near shoulder level, above the entrant’s head, or at another point which the company can establish that presents a profile small enough for the successful removal of the entrant; and
ii) The other end of the retrieval line shall be attached to a tripod lifting hoist for vertical retrieval methods and otherwise secured outside of the Permit Space.
e) Atmospheric Testing Procedures:
After all prior steps are successfully achieved, atmospheric testing must be performed prior to allowing entry. The following steps are to be followed when testing the atmosphere of a Permit Space:
i) All of the manufacturer's operating instructions must be followed;
ii) The test equipment should be tested in a known atmosphere to insure its accuracy;
iii) Ventilation equipment must be shut off before conducting any atmospheric tests;
iv) The atmosphere must be tested at the bottom, top, and middle of all Permit Spaces;
v) The atmosphere must be continuously monitored while work is being conducted in the Permit Space; and
vi) If the Permit Space is left for any reason, the atmosphere must be re-tested before re-entering the Permit Space.
f) Permit Space Cleaning:
If cleaning must be conducted in a Permit Space to achieve acceptable atmospheric conditions, the following procedures must be followed:
i) All Authorized Entrants must be equipped with the safety equipment designated;
15 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
ii) All Authorized Entrants must be equipped with appropriate PPE, including respiratory protection;
iii) No spark-producing tools will be allowed for use; and
iv) Appropriate cleaning procedures shall be developed.
g) Emergency and Rescue Procedures:
In the event of an emergency, the Attendant should:
i) Immediately notify the Entry Supervisor, 911, and/or other local emergency medical services (EMS) for immediate assistance.
ii) Attempt to remove Authorized Entrants by use of the retrieval line from outside the Permit Space, if this can be accomplished without creating further hazard for the entrant or the Attendant.
iii) If the Attendant is able to remove the Authorized Entrants with the retrieval line, he or she should administer aid within the limits of his or her training until EMS arrives.
iv) If the Attendant is unable to remove the Authorized Entrants by using the retrieval line, he or she must wait for help to arrive. The Attendant shall not enter the Permit Space for any reason.
v) Provide EMS personnel with all available information. If an injured entrant is exposed to a substance for which a MSDS or other similar written information is required to be kept at the site, that MSDS or other written information shall be made available to EMS.
4) RESPONSIBILITY
a) Management shall:
i) provide and verify that equipment, materials and PPE are available;
ii) monitor and enforce program compliance; and
iii) provide and verify training for employees covered by this program.
b) Entry Supervisors shall:
i) know the hazards that may be faced during entry, including the mode, signs or symptoms, and consequences of the exposure;
16 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
ii) verify that the required atmospheric tests are performed at the Permit Space and results are recorded on the permit prior to entry authorization;
iii) obtain and maintain all equipment necessary to complete the Permit Space entry project;
iv) authorize entry by signing the entry authorization space on the Entry Permit after all conditions for a safe entry have been met;
v) terminate the entry and cancel the permit when:
(1) entry operations covered by the Entry Permit have been completed, or
(2) a condition that is not allowed under the Entry Permit arises in or near the Permit Space.
vi) verify that rescue services are available and that the means for summoning them are operable;
vii) remove unauthorized individuals who enter or who attempt to enter the Permit Space during entry operations; and
viii) determine 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 shall remain consistent with terms of the Entry Permit and that acceptable entry conditions shall be maintained.
c) Authorized Entrants shall:
i) know the hazards that may be faced during entry, including the mode, signs or symptoms, and consequences of the exposure;
ii) properly use equipment, which includes:
(1) atmospheric testing and monitoring equipment;
(2) ventilating equipment needed to obtain acceptable entry conditions;
(3) communication equipment necessary to maintain contact with the Attendant;
(4) PPE as needed;
(5) lighting equipment as needed;
(6) barriers and shields as needed;
(7) equipment, such as ladders, needed for safe ingress and egress;
(8) emergency and rescue equipment as needed; and/or
17 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
(9) any other equipment necessary for safe entry into and rescue from Permit Spaces.
iii) communicate with the Attendant as necessary to enable the Attendant to monitor entrant status and to enable the Attendant to alert entrants of the need to evacuate the space if required;
iv) alert the Attendant (standby person) whenever:
(1) an Authorized Entrant recognizes any warning sign or symptom of exposure to a dangerous situation; or
(2) an Authorized Entrant detects a prohibited condition.
v) exit the Permit Space as quickly as possible whenever:
(1) an order to evacuate has been given by the Attendant or the Entry Supervisor;
(2) an Authorized Entrant recognizes any warning sign or symptom of exposure to a dangerous situation;
(3) an Authorized Entrant detects a prohibited condition; or
(4) an evacuation alarm is activated.
d) Attendants shall:
i) know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of exposure;
ii) be aware of possible behavioral effects of hazard exposure in Authorized Entrants;
iii) continuously maintain an accurate count of Authorized Entrants in the Permit Space and ensure that the means used to identify Authorized Entrants accurately identifies who is in the Permit Space;
iv) remain outside the Permit Space during entry operations until relieved by another Attendant;
v) attempt non-entry rescue if proper equipment is in place and the rescue attempt will not present further hazards to the Authorized Entrants or Attendant;
vi) communicate with Authorized Entrants as necessary to monitor Authorized Entrant status and to alert Authorized Entrants of the need to evacuate the space when conditions warrant;
18 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
vii) monitor activities inside and outside the Permit Space to determine if it is safe for Authorized Entrants to remain in the Permit Space, and order the Authorized Entrants to evacuate the Permit Space immediately under any of the following conditions:
(1) if the Attendant detects a prohibited condition;
(2) if the Attendant detects the behavioral effects of hazard exposure in an Authorized Entrant;
(3) if the Attendant detects a situation outside the space that could endanger the Authorized Entrants; or
(4) if the Attendant cannot effectively and safely perform all the duties required by this program.
viii) summon emergency and rescue and services as soon as the Attendant determines that Authorized Entrants may need assistance to escape from Permit Space hazards;
ix) take the following actions when unauthorized persons approach or enter a Permit Space while entry is underway:
(1) warn the unauthorized persons that they must stay away from the Permit Space;
(2) advise the unauthorized persons that they must exit immediately if they have entered the Permit Space; and
(3) inform the Authorized Entrants and the Entry Supervisor if unauthorized persons have entered the Permit Space.
x) perform no duties that might interfere with the Attendant's primary duty to monitor and protect the Authorized Entrants.
5) DEFINITIONS
a) Attendant - An employee designated by the site supervisor in charge of entry to remain outside the Permit Space and to be in constant communication with the Authorized Entrant(s) working inside the Permit Space.
b) Authorized Entrant - An employee who is approved or assigned by the site supervisor in charge of the entry to enter the Permit Space.
c) Bonding - The joining of two or more items with an electrical conductor so that all ends joined have the same electrical charge or potential.
19 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
d) Confined Space - A space that:
i) is large enough and so configured that an employee can bodily enter and perform assigned work;
ii) has limited or restricted means for entry or exit (e.g. Tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and
iii) is not designed for continuous employee occupancy.
e) Entry Permit - The written or printed document that is provided by the Company to allow and control entry into a Permit Space and that contains the information specified in this program. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the Authorized Entrant's body breaks the plane of an opening into the space. A sample Permit is provided as part of this Program.
f) Entry Supervisor – The site supervisor or the designated representative (such as the foreman or crew chief) responsible for determining if acceptable Entry conditions are present at a Permit Space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required by this program. Note: An Entry Supervisor also may serve as an Attendant or as an Authorized Entrant, as long as that person is trained and equipped as required by this program for each role he or she fills. Also, the duties of Entry Supervisor may be passed from one individual to another during the course of entry operation.
g) Flammable Atmosphere - Flammable Atmospheres are generally the result of flammable gases, vapors or dust mixed in certain concentrations with air, or an Oxygen-Enriched Atmosphere. A Flammable Atmosphere is considered when the lower explosive (LEL) or flammable limit (LFL) is greater than 10%. h) Hazardous Atmosphere - An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a Permit Space), injury, or acute illness from one or more of the following causes:
i) flammable gas, vapor, or mist in excess of 10% of its LEL or LFL.
ii) airborne combustible dust at a concentration that meets or exceeds its LEL.
NOTE: This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet or less.
iii) atmospheric oxygen concentration below 19.5% or above 23.5%.
iv) atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in Subpart G, Occupational Health and Environmental Control, or in Subpart Z, Toxic and Hazardous
20 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
Substances, of 29 CFR 1910 and that could result in employee exposure in excess of its dose or permissible exposure limit. An atmospheric concentration of any substance that is not capable of causing death, incapacitation, impairment of ability to self-rescue, injury, or acute illness due to its health effects is not covered by this provision.
v) any other atmospheric condition that is Immediately Dangerous to Life or Health (IDLH).
NOTE: For air contaminants for which OSHA has not determined a dose or permissible exposure limit, other sources of information, such as Material Safety Data Sheets that comply with the Hazard Communication Standard, 29 CFR 1910.1200, published information, and internal documents can provide guidance in establishing acceptable atmospheric conditions.
i) Hot Work - Any work involving burning, welding or similar fire-producing operations. Also, any work that produces a source of ignition, such as grinding, drilling, or heating.
j) Hot Work Permit - The Company's written authorization to perform operations (for example, riveting, welding, cutting, burning, and heating) capable of providing a source of ignition.
k) Immediately Dangerous to Life or Health (IDLH) - An atmosphere that poses an immediate threat of loss of life, or that would cause irreversible adverse health effects or that would impair escape unaided from a Confined Space.
l) Lower Explosive Limit (LEL) - The minimum concentration of a combustible gas or vapor in air that will ignite if an ignition source is introduced.
m) Non-Permit Confined Space - a Confined Space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm.
n) Oxygen-Deficient Atmosphere - An atmosphere that contains an oxygen concentration of less than 19.5% by volume.
o) Oxygen-Enriched Atmosphere - An atmosphere that contains an oxygen concentration greater than 23.5% by volume.
p) Personal Protective Equipment (PPE) - Any device or clothing worn by the worker to protect against hazards in the environment. Examples are respirators, gloves, and chemical splash goggles.
q) Permissible Exposure Level (PEL) - Concentration of a substance to which an individual may be exposed repeatedly without adverse effect.
21 of 22
GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM CONFINED SPACE ENTRY PROGRAM
r) Permit-Required Confined Space (also “Permit Space”) - A Confined Space that has one or more of the following characteristics:
i) contains or has potential to contain a hazardous atmosphere;
ii) contains a material that has the potential for engulfing an entrant;
iii) has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; and/or
iv) contains any other recognized serious safety or health hazard.
s) Purging - The removal of gases or vapors from a Confined Space by the process of displacement.
22 of 22
Ronald Tracy Evans, CEO
EMERGENCY RESPONSE PLAN GEO FOSSIL FUELS, TABULA RASA ENERGY, PERDURE PETROLEUM ______LOCATION
TABLE OF CONTENTS
A. Purpose of Program ...... Page (s) 2
B. Building Emergency Organization ...... 2-3
C. Notification Procedures and Communication Systems ...... 3-4
D. Emergency Equipment and Facilities ...... 4
E. Training and Drills ...... 4
F. Plan Review and Updates ...... 4-5
G. Emergency Response Procedures ...... 5-7
H. Bomb Threat ...... 7-8
EMERGENCY RESPONSE PLAN Page 1 of 8
A. PURPOSE OF PROGRAM
This program is to provide for the safety of the employees of Geo Fossil Fuels, Tabula Rasa Energy and Perdure Petroleum in the event of emergencies such as fire, explosion, chemical release or other accidents.
This Emergency Response (ER) plan is developed to provide guidelines for the handling of emergencies, training procedures for employees, evacuation, and coordination of efforts with any governmental agencies or other emergency organizations which may be involved.
B. BUILDING EMERGENCY ORGANIZATION
1. Emergency Response Coordinator
Employee Name is designated as the Emergency Response Coordinator (ERC). The ERC is responsible for the overall program in its design, implementation, and use.
Employee Name is to be the primary contact in any emergency. His phone numbers are: • Office number: • Cell number is • Home number:
The ERC is considered the person in charge and will respond to all facility emergencies. In his/her absence, the alternates are as listed in line of authority below:
Name Position Telephone
Employee Name First Alternate Office: Cell: Home:
Employee Name Second Alternate Office: Cell: Home:
2. Key Response Assignments
The ERC will designate the individual responsibilities and assign alternates in the following areas based on who is on duty at the time of the incident:
• Person to Notify Authorities: This person is responsible for notifying the local authorities in case of emergency. There will be two designated individuals for this purpose.
EMERGENCY RESPONSE PLAN Page 2 of 8
• Evacuation Coordinator: The Coordinator and alternate will be responsible for evacuation of personnel, proceeding to the gathering point and determining missing employees. They will also be responsible for using fire extinguishers at the early stages of a fire and securing office during evacuation.
• Spotter: The Spotter and alternate will be responsible for meeting at a prearranged location to direct the fire department or emergency medical services vehicles.
A listing of all employees and the various contact numbers is attached.
C. NOTIFICATION PROCEDURES AND COMMUNICATIONS SYSTEMS
The ERC is responsible for the establishment of communication systems within the emergency organization, and with local officials and response agencies.
Listed below are the local agencies who will respond in emergencies. All agencies can be contacted by dialing 911.
• Fire Department • Police Department • Ambulance
In addition, the ERC will insure the appropriate parties are notified in accordance with any of the following plans that may be applicable:
• Facility Response Plan (FRP) • Operations, Maintenance and Emergency (OME) Manual • Spill Prevention, Control and Countermeasures (SPCC) Plan • Hazardous Waste Operations and Emergency Response (HAZWOPPER) Plan • H2S Contingency Plan • Naturally Occurring Radioactive Materials (NORM) Manual
The ERC and alternate in an emergency will designate the following communication responsibilities:
• A designated person for media contacts • A designated representative to notify families of affected employees • Establishment of a central reporting office utilizing designated portable phones
EMERGENCY RESPONSE PLAN Page 3 of 8
Where appropriate, the Incident Command System (ICS) established by the National Incident Management System (NIMS) may be implemented for site emergencies, spills, and releases. The command and support roles of the ICS will be established by the Sr. Safety Officer and coordinated with the ERC for each location and may be assigned to both Company employees and contract personnel. In accordance with ICS guidelines, the size of the incident command structure can be reduced or expanded to match the scope of the response.
D. EMERGENCY EQUIPMENT AND FACILITIES
The local Operations Superintendent is responsible for:
• Insuring that all firefighting equipment is inspected on a monthly basis with written records, to ensure that the equipment is serviceable and ready for use. • Insuring that emergency medical supplies are well stocked and available.
E. TRAINING AND DRILLS
The ERC in coordination with the Operations Superintendent is responsible for insuring that training is provided for all employees in Emergency Response Procedures.
The following information must be reviewed with all employees.
• Procedures for reporting emergencies • Location of firefighting equipment • Use of firefighting equipment • Evacuation procedures • Frequent, documented simulated emergencies
F. PLAN REVIEW AND UPDATES
The ERC is responsible for an annual review of the existing Emergency Response Program to determine areas of needed improvement. This review must be documented, and any changes noted in the update of the written program, with such changes reflected in the training of all employees. Plan updates can be made as a result of drills and tests indicating deficiencies in the program.
The ERC in coordination with the Operations Superintendent is responsible for:
• Conducting drills • Documented, frequent alarm tests • Frequent tests of firefighting equipment • Practice of evacuation procedures
EMERGENCY RESPONSE PLAN Page 4 of 8
G. EMERGENCY RESPONSE PROCEDURES
1. Communications
• In the event of emergency, the designated Person to Notify Authorities will call 911.
• The Person to Notify Authorities will insure notification of ERC or alternate.
• The Person to Notify Authorities will insure that any additional authorities are notified as outlined in the FRP, OME Manual, SPCC Plan, HAZWOPPER Plan, H2S Contingency Plan or NORM Manual.
• The Person to Notify Authorities will remain at the phone until relieved by ERC or notified of evacuation.
• All incoming calls will be referred to the ERC.
• The spotter will proceed to the designated area to direct responding emergency vehicles.
2. Evacuation
DO NOT USE ELEVATOR - USE STAIRS
• Evacuation of all personnel will begin immediately upon notification by the public address system, alarm system, ERC, any other member of supervision or coordinator.
• Employees will leave through the closest exit if possible. If the closest exit is not accessible, proceed to any other exit. After exit from building, proceed to the designated gathering point.
• Designated Exits are: o Main Office – # exits o Plant Facility– # exists
• Should you be in any conference/training area or any common area, assist visitors and use the nearest exit. Proceed to the designated gathering area with visitors.
• The Evacuation Coordinator will determine personnel present and report to ERC of any missing individuals.
EMERGENCY RESPONSE PLAN Page 5 of 8
• The ERC or other designated person is responsible for insuring that all power is shut down at the facility after evacuation.
• DO NOT LEAVE GATHERING POINT OR RE-ENTER BUILDING UNTIL NOTIFIED BY ERC, SUPERVISOR, OR ANOTHER COORDINATOR.
3. Fire
• Report fire to ERC or his alternates in priority order. The ERC or his alternate will either contact the Person to Notify Authorities who will call emergency personnel or contact them directly.
• Immediately attempt to put it out. Use fire extinguisher located at one of the locations listed below or cover with a wastebasket.
. Main Office - Fire extinguishers near main door and back door exits . Plant Facility - Fire extinguishers located throughout facility
• Close all interior and exterior doors. DO NOT LOCK.
• Evacuate if notified.
4. Medical
• Notify the ERC or his alternate. The ERC will either contact the Person to Notify Authorities who will call ambulance and emergency personnel or contact them directly.
• Provide ERC with employee name, department location, person calling and nature of emergency.
5. Bomb Threat
• Use "Bomb Threat Check List" to get as much information as possible.
• Individual receiving call:
o Signal (quietly) to another employee to get on same line. If unable to catch other employee's attention, throw pencil or some other object at nearest employee and hold up number of fingers indicating the line caller is on.
• Second employee:
EMERGENCY RESPONSE PLAN Page 6 of 8
o Quietly get on line, cover mouthpiece of phone and take notes.
o Signal another employee to notify ERC or his alternates who will call police.
• If only two employees are available, the second should act as above and not monitor call.
• Stand by for instructions.
6. Office Security
Theft can be a problem in all areas. Offices are normally unlocked during normal business hours, and delivery people, contractors and visitors may be in the building or facilities throughout the day. There are several measures you can take to help prevent someone from stealing items from your office or work space:
• Keep all valuables locked in desks when not attended.
• Keep expensive items off desk tops when not at desks.
• Notify supervisor when loiterers are observed in corridors or washrooms. Report any peddlers and canvassers.
• Special care should be taken during times best suited for pilferage - 30 minutes just after opening, during lunch hours and before closing - when there is a maximum of movement of personnel and absence from work areas and offices.
• Check wastebaskets at the end of the day to see if any equipment other valuables may have been accidentally thrown out.
• Should you feel office security is threatened by visitors or other outside individuals, contact your supervisor.
• Should threat occur, the supervisor will make appropriate announcement and notify authorities as well as ERC.
• ERC will determine appropriate response.
Should theft occur, report it to your supervisor as soon as it is discovered.
EMERGENCY RESPONSE PLAN Page 7 of 8
H. BOMB THREAT CHECK LIST
Telephone Procedures
1. Be calm, courteous; listen - do not interrupt.
2. Signal another employee to get on the same line (another phone) quietly and take notes. Throw something to get attention of another employee if necessary.
3. Circle items below that apply as you listen:
Time call received: Identify: Male/Female/Adult/Juvenile Voice: Loud/Soft/Normal/Intoxicated Other
Speech: Fast/Medium/Slow/Slurred/Foul Diction: Excellent/Good/Fair/Poor Accent: Other Manner: Calm/Angry/Rational/Irrational Background Noises: Street/Offices/Voices/Music/Bar/Cafeteria Other
4. Ask:
Location of bomb? (Exact) Time set to explode? What kind of bomb? Why?
Legitimate caller usually wants to avoid injuries or deaths. Request as much information as possible by expressing a desire to save lives.
Time:
Name of Person Receiving Call:
Extension No.:
Date:
Time Completed:
EMERGENCY RESPONSE PLAN Page 8 of 8 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HAZARDOUS COMMUNICATION (HAZCOM) PROGRAM
1) PURPOSE AND SCOPE
The purpose of this program is to establish policies and procedures for receipt, safe use, safe handling and safe storage of chemicals in the workplace and providing information concerning their hazards to employees.
Reference: OSHA Standard 29 CFR 1910.1200.
2) POLICY
a) Requirement/Use:
i) All chemicals shall be used in accordance with the Material Safety Data Sheet (MSDS) and Container labels.
ii) Substitute less toxic materials whenever possible.
iii) Limit the amount of chemical kept at work stations to the minimum needed for the operational period.
iv) Provide an approved means of containing the chemical if equipment or Containers should leak and/or spill their contents.
b) Before Using Chemicals (User Chemical Awareness):
Before using chemicals, the user shall be informed of the following information on the MSDS and/or Container labels:
i) Fire and explosion information:
(1) Flashpoint, Auto-Ignition Temperature and upper/lower flammability limits;
(2) any unusual fire or explosive hazards;
(3) proper fire extinguishing agents to use; and
(4) fire fighting techniques.
ii) Chemical reaction information:
(1) stability of chemicals;
(2) conditions and/or materials to be avoided; and
(3) other hazardous substances, vapors, etc. that can be produced when chemical reacts.
1 of 10 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HAZARDOUS COMMUNICATION (HAZCOM) PROGRAM
iii) Control measures:
(1) engineering controls required for safe use of chemical;
(2) Personal Protective Equipment (PPE) required for use of chemical;
(3) safe handling guidelines; and
(4) safe storage requirements.
iv) Health hazards:
(1) Routes of Entry into the body;
(2) acute and chronic symptoms/effects on person;
(3) medical conditions that can be made worse by exposure to chemical;
(4) Permissible Exposure Limit (PEL) and Threshold Limit Value (TLV);
(5) cancer causing properties, if any; and
(6) emergency and first aid treatments.
v) Spill and leak:
(1) clean-up methods;
(2) hazard controls (engineering, administrative, PPE); and
(3) disposal of waste and clean-up material.
c) Equipment/Materials (Chemical Containers):
i) Each chemical Container shall be used in accordance with its designed purpose.
ii) Marking/Labeling:
(1) Each chemical Container shall be labeled with its contents and potential hazards and shall be marked and labeled in accordance with the requirements of this program.
(2) Marking and labeling shall remain legible at all times. If worn out or otherwise not readable or visible, such marking and labeling shall be replaced.
2 of 10 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HAZARDOUS COMMUNICATION (HAZCOM) PROGRAM
(3) If a label cannot be affixed to a Container, the Container will be identified by posting a sign in the area of work which shall meet the requirements of this program and be readily available to employees in the work area.
iii) Each chemical shipment shall be inspected to ensure that it contains a MSDS and is properly labeled as required by this program.
iv) Chemical Containers shall be approved for the intended contents.
v) Chemical Containers shall be maintained in a serviceable condition. They shall be properly disposed of if not in a serviceable condition.
d) Chemical storage:
i) Chemicals shall be stored to eliminate the possibility of unwanted chemical reactions, fires or any undesired and/or unplanned event.
ii) Chemicals shall be stored in accordance with MSDS requirements and recommendations, or other appropriate industry standards.
iii) Chemicals shall not be stored in any refrigerator used for food storage. If chemicals are stored in a refrigerator a warning label must be placed on the door, indicating chemical storage.
e) Container labels and methods of warning:
i) All Container warnings, labels, tags or markings shall contain the identity of the chemical and the appropriate hazard warnings, or alternatively, words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under this program, will provide employees with specific information regarding the physical and health hazards of the chemical.
ii) All warning labels, tags and markings shall be maintained in a legible condition and not defaced, shall be in English, and shall be prominently affixed to Container.
iii) Labels must represent the actual chemical in the Container.
iv) Any Container of chemicals not properly labeled, tagged or marked shall not be accepted by the Company.
v) Existing labels shall not be removed or defaced unless the Container is immediately marked with the required information.
vi) The National Fire Protection Association (NFPA) 704M (fire diamond) or Hazardous Materials Identification System (HMIS) label will suffice on all stationary and semi-portable chemical Containers in the workplace
3 of 10 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HAZARDOUS COMMUNICATION (HAZCOM) PROGRAM
vii) Portable Containers into which a small amount of chemical is transferred from a labeled Container need not be labeled:
(1) if they are used immediately during a shift; and
(2) if they are under the strict control of the employee using the product.
f) Chemical Inventory List:
i) A list of all hazardous chemicals used by the Company (the “Chemical Inventory List”) shall be compiled in accordance with the requirements of the “Documentation and Recordkeeping.”
ii) The Chemical Inventory List shall be used to lookup and readily find the chemical, rather than looking through every MSDS. Printed copies of MSDS’s will be available at each facility for the chemicals used and/or stored at that facility and shall be accessible to employees during each work shift.
g) Right-to-Know (RTK) Station
i) RTK stations shall be available for employee use and reference.
ii) RTK stations shall be located in designated locations.
iii) RTK stations shall be clearly marked.
iv) RTK stations shall include:
(1) a current copy of the HAZCOM Program;
(2) a current Chemical Inventory List; and
(3) current Material Safety Data Sheets
h) Contractors
i) All contractors working inside Company facilities are required to follow the requirements of this program.
ii) Supervisors shall provide information to contractors concerning:
(1) the location of RTK station and MSDS’s;
(2) precautions to be taken to protect contractor’s personnel;
(3) potential exposure to chemicals;
(4) chemicals used in or stored in areas where they will be working;
4 of 10 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HAZARDOUS COMMUNICATION (HAZCOM) PROGRAM
(5) recommended personal protective equipment; and
(6) labeling system in use for chemicals.
i) Non-English Speaking Employees: For employees who speak other languages, the Company may add the information in their language to the material presented, as long as the information is presented in English as well.
j) Documentation and Recordkeeping:
i) The Company shall provide affected employees with access to the HAZCOM Program and related documents in accordance with the requirements of 29 CFR 1910.1200.
ii) The Company shall have a MSDS in the workplace for each hazardous chemical it uses. The MSDS shall contain the following information:
(1) identity used on the label, and
(a) if the chemical is a single substance, its chemical and common name;
(b) if the chemical is a mixture which has been tested as whole to determine its hazards, the chemical and common names of the ingredients contributing to the known hazards and common name of the mixture itself; and
(c) if the chemical has not been tested as a whole:
(i) the chemical and common names of all ingredients which have been determined to be health hazards, and which comprise 1% or greater of the composition, except that chemicals identified as carcinogens shall be listed if the concentrations are 0.1% or greater;
(ii) the chemical and common names of all ingredients which have been determined to be health hazards, and which comprise less than 1% (0.1% for carcinogens) of the mixture, if there is evidence that the ingredient(s) could be released from the mixture in concentrations which would exceed an established OSHA PEL or American Conference of Governmental Industrial Hygienists (ACGIH) TLV, or could present a health risk to employees; and
(iii) the chemical and common names of all ingredients which have been determined to present a physical hazard when present in the mixture.
(2) physical and chemical characteristics of the hazardous chemical;
5 of 10 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HAZARDOUS COMMUNICATION (HAZCOM) PROGRAM
(3) health hazards of the hazardous chemical, including signs and symptoms of exposure, and any medical conditions which are generally recognized as being aggravated by exposure to the chemical;
(4) primary Routes of Entry;
(5) OSHA PEL, ACGIH TLV, and any other exposure limit used or recommended by the chemical manufacturer, importer, or company preparing the MSDS where available;
(6) whether the hazardous chemical is listed in the National Toxicology Annual Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer Monographs (latest editions) or by OSHA;
(7) generally applicable precautions for safe handling;
(8) generally applicable control measures;
(9) emergency and first aid procedures;
(10) date of preparation of the MSDS or last change to it; and
(11) name, address, and telephone number of chemical manufacturer, importer, company or other responsible party preparing or distributing the MSDS who can provide additional information on the hazardous chemical and appropriate emergency procedures if necessary .
iii) Chemical Inventory List:
The Chemical Inventory List shall follow these requirements:
(1) the name of every chemical used by the Company shall be listed on the Chemical Inventory List;
(2) the referenced name on the Chemical Inventory List shall be the same as the chemical name listed on the MSDS;
(3) shall be listed in alphabetical order; and
(4) shall be kept current.
iv) Training certifications:
(1) The Company shall certify that employee training has been accomplished.
(2) The certification shall contain each employee’s name and dates of
6 of 10 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HAZARDOUS COMMUNICATION (HAZCOM) PROGRAM
training.
(3) Documentation of training will be maintained by the Company.
k) Training and Communication:
i) Training shall be provided to all new hires covering the elements of this HAZCOM Program and shall consist of the following topics:
(1) existence and requirements of 29 CFR 1910.1200;
(2) operations where hazardous chemicals are present;
(3) location of the right-to-know station;
(4) location and availability of the written HAZCOM Program;
(5) location and availability of the Chemical Inventory List;
(6) location and use of MSDS sheets;
(7) explanation of chemical labeling system;
(8) methods and observations used to detect the presence or release of a chemical in the workplace;
(9) the specific physical and health hazards of all chemicals in the workplace; and
(10) specific control measures for personal protection from physical and health hazards.
ii) Training shall also be provided to existing employees whenever a new physical or health hazard is identified.
iii) HAZCOM training shall be performed annually for all affected employees. Computer based training (CBT) may be utilized to fulfill training requirements.
iv) Employees shall be retrained upon request or whenever employees exhibit a lack of understanding regarding chemical safety or use.
v) Company shall certify that employee training has been completed. For required content of the training certification, see “Documentation and Recordkeeping.”
3) PROCEDURES
7 of 10 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HAZARDOUS COMMUNICATION (HAZCOM) PROGRAM
a) Non-Routine Tasks: Non-Routine Tasks shall be evaluated before an employee may begin work on such a task to determine the hazards and objectives of the work. Before an employee begins a Non-Routine Task involving the use of chemicals or potential chemical exposure, the supervisor will inform the employee of the necessary information about the hazardous chemicals the employee will be working with while performing the task. This information will include the specific chemical hazards and the protective equipment required. Training will be documented and marked as “Non-Routine Task Training.”
b) Emergencies:
During emergencies follow these guidelines:
i) Minimize exposure by removing and evacuating all potentially affected employees.
ii) Follow emergency response procedures in the MSDS.
4) RESPONSIBILITY
a) Management shall:
i) promote and enforce program compliance;
ii) conduct immediate corrective action for deficiencies found in the program; and
iii) make this plan available to employees or their designated representatives.
b) Supervisors shall:
i) comply with all specific requirements of the program;
ii) provide chemical specific safety training for assigned employees;
iii) verify chemicals are properly used, stored and labeled;
iv) verify only the minimum amount of chemical necessary is kept at work stations;
v) comply with Non-Routine Tasks procedure;
vi) comply with “Contractor” requirements of this program; and
vii) keep the Chemical Inventory List current.
c) Purchasing/Shipping and Receiving shall:
8 of 10 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HAZARDOUS COMMUNICATION (HAZCOM) PROGRAM
i) verify vendors supply current MSDS’s for chemicals;
ii) obtain, from the manufacturer, MSDS’s for chemicals purchased from retail sources;
iii) verify that Containers purchased for chemical use are appropriate for the purpose;
iv) verify that vendor chemical Containers are properly labeled;
v) verify all received Containers are properly labeled and that labels are not removed or defaced; and
vi) verify all shipped Containers are properly labeled.
d) Employees shall:
i) comply with the safety requirements of this program;
ii) use chemicals only for the specific assigned tasks in accordance with manufacturer recommendations and Company policy;
iii) report any problems with the use or storage of chemicals to their supervisor; and
iv) immediately report chemical spills.
5) DEFINITIONS
a) Auto-Ignition Temperature – The minimum temperature at which a substance ignites without application of a flame or spark.
b) Chemical Inventory List – A list of all hazardous chemicals used by the Company which contains the information required by the “Documentation and Recordkeeping.”
c) Container – Any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains chemicals. For purposes of this section, pipes or piping systems, and engines, fuel tanks or other operating systems in a vehicle are not considered to be Containers.
d) Flammable Limits (Flammability Limits, Explosive Limits) – Minimum and maximum concentrations of a flammable gas or vapor between which ignition can occur. Concentrations below the lower flammable limit (LFL) are too lean to burn, while concentrations above the upper flammable limit (UFL) are too rich to burn. All concentrations between LFL and UFL are in the flammable range, and special precautions are needed to prevent ignition or explosion.
9 of 10 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HAZARDOUS COMMUNICATION (HAZCOM) PROGRAM
e) Flashpoint (FP) – Lowest temperature at which a flammable liquid gives off sufficient vapor to form an ignitable mixture with air near its surface or within a vessel.
f) Health Effects
i) Acute effects – Adverse effects on a human or animal body, with symptoms developing rapidly.
ii) Chronic effects – Adverse effects on a human or animal body with symptoms that develop slowly over a long time period and persist or that recur frequently.
g) Material Safety Data Sheet (MSDS) – Written or printed material concerning a hazardous chemical which contains the information required by the “Documentation and Recordkeeping,” including, but not limited to, information about material identification; hazardous ingredients; health, physical and fire hazards; first aid; chemical reactivities and incompatibilities; spill, leak and disposal procedures; and protective measures required for safe handling and storage.
h) Non-Routine Task – A task such as working on, near or within unlabeled piping, unlabeled Containers of an unknown substance, any area, work or task where chemicals may be present.
i) Permissible Exposure Limit (PEL) – The amount of a substance a worker can be exposed up to without having any adverse Health Effects as established by OSHA. This may be expressed as a time-weighted average (TWA) limit, a short- term exposure limit (STEL), or as a ceiling exposure limit. A ceiling limit must never be exceeded.
j) Routes of Entry – The way a chemical enters the body; inhalation, absorption (skin, mucous membrane), ingestion or injection.
k) Threshold Limit Value (TLV) – Same definition as PEL but developed by the American Conference of Governmental Industrial Hygienists (ACGIH).
10 of 10 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HEARING CONSERVATION PROGRAM
1) PURPOSE AND SCOPE
The purpose of this program is to protect employees from excessive noise exposure by recognizing excessive noise, taking steps to protect employees’ hearing, and continuously monitoring employees’ hearing to determine the effectiveness of the protective measures being executed and maintained.
Reference: OSHA Standard 29 CFR 1910.95
2) POLICY
a) Hearing Conservation Program: The Company shall administer this continuing, effective program, as described in the remainder of this 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 scale (slow response) or, equivalently, a dose of 50 percent (referred to herein as “Action Level”). For purposes of this program, employee noise exposures shall be computed in accordance with 29 CFR 1910.95 Appendix A: Noise Exposure Computation and Table G-16a and without regard to any attenuation provided by the use of personal protective equipment.
b) Monitoring:
i) When information indicates that any employee’s exposure may equal or exceed an 8-hour TWA of 85 db, the Company shall implement a monitoring program.
(1) The sampling strategy shall be designed to identify employees for inclusion in the Hearing Conservation Program and to enable the proper selection of hearing protectors.
(2) Where circumstances such as high worker mobility, significant variations in sound level or a significant component of impulse noise make area monitoring inappropriate, the Company shall use representative personal sampling to comply with the monitoring requirements of this program unless the Company can show that area sampling produces equivalent results.
ii) All continuous, intermittent and impulsive sound levels from 80 db to 130 db shall be integrated into the noise measurements.
iii) Instruments used to measure employee noise exposure shall be calibrated to ensure measurement accuracy.
iv) Monitoring shall be repeated whenever a change in production, process, equipment or controls increases noise exposures to the extent that:
1 of 8 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HEARING CONSERVATION PROGRAM
(1) additional employees may be exposed at or above the action level; or
(2) the attenuation provided by hearing protectors being used by employees may be rendered inadequate to meet the requirements of the hearing protector attenuation section of this program.
c) Employee Notification: The Company shall notify each employee exposed at or above an 8-hour TWA of 85 db of the results of the monitoring.
d) Observation of Monitoring: The Company shall provide affected employees or their representatives with an opportunity to observe any noise measurements conducted.
e) Audiometric Testing Program:
i) The Company shall establish and maintain an audiometric testing program as provided in this section by making audiometric testing available to all employees whose exposures equal or exceed an 8-hour TWA of 85 decibels.
ii) The program shall be provided at no cost to employees.
iii) Audiometric tests shall be performed by a licensed or certified audiologist, otolaryngologist, or other physician, or by a technician who is certified by the Council of Accreditation in Occupational Hearing Conservation, or who has satisfactorily demonstrated competence in administering audiometric examinations, obtaining valid audiograms, and properly using, maintaining and checking calibration and proper functioning of the audiometers being used. A technician who operates microprocessor audiometers does not need to be certified. A technician who performs audiometric tests must be responsible to an audiologist, otolaryngologist or physician.
iv) All audiograms obtained pursuant to this section shall meet the requirements of 29 CFR 1910.95 Appendix C: Audiometric Measuring Instruments.
v) Baseline audiogram:
(1) Within 6 months of an employee's first exposure at or above the action level, the Company shall establish a valid baseline audiogram against which subsequent audiograms can be compared.
(2) Mobile test van exception: Where mobile test vans are used to meet the audiometric testing obligation, the Company shall obtain a valid baseline audiogram within 1 year of an employee's first exposure at or above the action level. Where baseline audiograms are obtained more than 6 months after the employee's first exposure at or above the action level, employees shall wear hearing protectors for any period exceeding 6 months after first exposure until the baseline audiogram is obtained.
2 of 8 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HEARING CONSERVATION PROGRAM
(3) Testing to establish a baseline audiogram shall be preceded by, at least, 14 hours without exposure to workplace noise. Hearing protectors may be used as a substitute for the requirement that baseline audiograms be preceded by 14 hours without exposure to workplace noise.
(4) The Company shall notify employees of the need to avoid high levels of non-occupational noise exposure during the 14-hour period immediately preceding the audiometric examination.
vi) Annual audiogram: At least annually after obtaining the baseline audiogram, the Company shall obtain a new audiogram for each employee exposed at or above an 8-hour TWA of 85 db.
vii) Evaluation of audiogram:
(1) Each employee's annual audiogram shall be compared to that employee's baseline audiogram to determine if the audiogram is valid and if there has been a Standard Threshold Shift, as defined below. This comparison may be done by a technician.
(2) If the annual audiogram shows that an employee has suffered a Standard Threshold Shift, the Company may obtain a retest within 30 days and consider the results of the retest as the annual audiogram.
(3) The audiologist, otolaryngologist, or physician shall review problem audiograms and shall determine whether there is a need for further evaluation. The Company shall provide to the person performing this evaluation the following information:
(a) a copy of the requirements for hearing conservation as set forth in this program;
(b) the baseline audiogram and most recent audiogram of the employee to be evaluated;
(c) measurements of background sound pressure levels in the audiometric test room as required in 29 CFR 1910.95 Appendix D: Audiometric Test Rooms; and
(d) records of audiometer calibrations required by paragraph 29 CFR 1910.95 (h)(5).
viii) Follow-up procedures:
(1) If a comparison of the annual audiogram to the baseline audiogram indicates a Standard Threshold Shift, as defined below, the employee shall be informed of this fact in writing, within 21 days of the determination.
3 of 8 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HEARING CONSERVATION PROGRAM
(2) Unless a physician determines that the Standard Threshold Shift is not work related or aggravated by occupational noise exposure, the Company shall take the following steps when a Standard Threshold Shift occurs:
(a) Employees not using hearing protectors shall be fitted with hearing protectors, trained in their use and care, and required to use them.
(b) Employees already using hearing protectors shall be refitted and retrained in the use of hearing protectors and provided with hearing protectors offering greater attenuation if necessary.
(c) The employee shall be referred for a clinical audiological evaluation or an otological examination, as appropriate, if additional testing is necessary or if the Company suspects that a medical pathology of the ear is caused or aggravated by the wearing of hearing protectors.
(d) The employee is informed of the need for an otological examination if a medical pathology of the ear that is unrelated to the use of hearing protectors is suspected.
(3) If subsequent audiometric testing of an employee, whose exposure to noise is less than an 8-hour TWA of 90 db, indicates that a Standard Threshold Shift is not persistent, the Company:
(a) shall inform the employee of the new audiometric interpretation; and
(b) may discontinue the required use of hearing protectors for that employee.
ix) Revised baseline: An annual audiogram may be substituted for the baseline audiogram when, in the judgment of the audiologist, otolaryngologist or physician who is evaluating the audiogram:
(1) the Standard Threshold Shift revealed by the audiogram is persistent; or
(2) the hearing threshold shown in the annual audiogram indicates significant improvement over the baseline audiogram.
x) Standard Threshold Shift:
(1) A Standard Threshold Shift is 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.
(2) In determining whether a Standard Threshold Shift has occurred, allowance may be made for the contribution of aging (presbycusis) to the change in hearing level by correcting the annual audiogram according to the procedure described in 29 CFR 1910.95 Appendix F: Calculation and Application of Age Correction to Audiograms.
4 of 8 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HEARING CONSERVATION PROGRAM
f) Equipment/Materials (Hearing Protectors):
i) The Company shall make hearing protectors available to all employees exposed to an 8-hour TWA of 85 db or greater at no cost to the employees.
ii) Hearing protectors shall also be provided where noise exceeds limits.
iii) Hearing protectors shall be replaced as necessary.
iv) Supervisors shall verify proper initial fitting and supervise the correct use of all hearing protectors.
v) Supervisors shall verify that hearing protectors are worn:
(1) by employees who are required to wear them in accordance with the permissible noise exposure table;
(2) by employees who are exposed to an 8-hour TWA of 85 db or greater and who:
(a) have not yet had a baseline audiogram established; or
(b) have experienced a Standard Threshold Shift.
vi) Selection:
(1) The Company shall evaluate hearing protector attenuation for the specific noise environments in which the protector shall be used.
(2) Hearing protectors must attenuate employee exposure at least to an 8- hour TWA of 90 db.
(3) For employees who have experienced a Standard Threshold Shift, hearing protectors must attenuate employee exposure to an 8-hour TWA of 85 db or below.
(4) Employees shall be given the opportunity to select their hearing protectors from a variety of suitable hearing protectors provided by the Company.
(5) The adequacy of hearing protector attenuation shall be re-evaluated whenever employee noise exposures increase to the extent that the hearing protectors provided may no longer provide adequate attenuation. The Company shall provide more effective protectors where necessary.
(6) The Company shall use one of the evaluation methods described in 29 CFR 1910.95 Appendix B: Methods for Estimating the Adequacy of Hearing Protection Attenuation.
5 of 8 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HEARING CONSERVATION PROGRAM
vii) Condition: Hearing protection shall be maintained in a serviceable condition and in accordance with manufacturer’s instructions.
g) Documentation and Recordkeeping:
i) Access to information and training materials:
(1) The Company shall make available to affected employees or their representatives copies of OSHA Standard 29 CFR 1910.95 and shall also post a copy in the workplace.
(2) The Company shall provide to affected employees any informational materials pertaining to the standard that are supplied to the Company by the Assistant Secretary.
(3) Upon request, the Company shall provide the Assistant Secretary and the Director (of the U.S. Department of Labor and OSHA) all materials related to the Company’s training and education program pertaining to this standard.
ii) Exposure measurements: The Company shall maintain an accurate record of all employee exposure measurements required by this program.
iii) Audiometric test records:
(1) The Company shall maintain all employee audiometric test records obtained required by this program. These records shall include:
(a) name and job classification of the employee;
(b) date of the audiogram;
(c) the examiner’s name;
(d) date of the last acoustic or exhaustive calibration of the audiometer; and
(e) employee’s most recent noise exposure assessment.
(f) accurate records of the measurements of the background sound pressure levels in audiometric test rooms.
iv) Record retention:
(1) Noise exposure measurement records shall be retained for two years.
(2) Audiometric test records shall be retained for the duration of the affected employee’s employment.
6 of 8 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HEARING CONSERVATION PROGRAM
v) All records required by this section shall be provided upon request to employees, former employees, representatives designated by the individual employee, and the Company’s counsel. The provisions of 29 CFR 1910.1020 (a)-(e) and (g)-(i) apply to records access.
vi) If the Company ceases to do business, the Company shall transfer to the successor employer all records required to be maintained by this program, and the successor employer shall retain them for the remainder of the period prescribed in this program.
vii) Training certifications:
(1) The Company shall certify in writing that employee training has been accomplished.
(2) The training certification shall contain each employee’s name and dates of training.
(3) Documentation of training will be maintained by the Company.
h) Training and Communication:
i) Training policy: The Company shall provide training in the use and care of all hearing protectors provided to employees.
ii) The Company shall maintain a training program for all employees who are exposed to noise at or above an 8-hour TWA of 85 db
iii) Each employee included in the Hearing Conservation Program shall be trained initially upon hire and annually thereafter. Information provided in the training program shall be updated to be consistent with changes in protective equipment and work processes.
iv) The Company training program ensures that each employee is informed of the following:
(1) the effects of noise on hearing;
(2) the purpose of hearing protectors, the advantages, disadvantages and attenuation of various types, and instructions on selection, fitting, use and care; and
(3) the purpose of audiometric testing and an explanation of the test procedures.
v) Retraining Policy:
7 of 8 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM HEARING CONSERVATION PROGRAM
Retraining shall be provided when employees required to use hearing protection:
(1) are not using hearing protection in accordance with hearing protection manufacturer’s instructions; or
(2) are observed NOT using hearing protection where and when required.
vi) The Company shall verify that each affected employee has received the appropriate hearing protection training and understands that training through a written certification. See “Documentation and Recordkeeping” for information regarding training certification.
3) RESPONSIBILITY
a) Management shall:
i) provide necessary audiometric testing and monitoring;
ii) provide hearing protectors as necessary; and
iii) provide hearing conservation training.
b) Supervisors shall:
i) verify employees wear hearing protection when required; and
ii) verify employees wear hearing protection properly.
c) Employees shall:
i) wear hearing protection in accordance with manufacturer’s instruction; and
ii) wear hearing protection when and where required.
4) DEFINITIONS
a) Decibel – The measure of a unit of sound, abbreviated db.
b) Standard Threshold Shift – 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.
8 of 8 Health, Safety and Environmental Policy Section 8 – Hot Work Carl Thunem – Director of Health, Safety & Environmental November 2018 Section 11: Hot Work Purpose and Scope
To establish proper safety precautions for the performance of work;
Requiring an open flame, or
Results in sparks, where
Releases of toxic, reactive, flammable or explosive materials,
Could result in a fire, explosion or uncontrolled emission. The GFF/Perdure/TRP JSA and Hot Work Permit are required in the presence of flammable or explosive materials when performing the following:
Electric or gas welding, cutting, brazing
Grinding, chipping, cutting concrete or metal with power or hand tools
Use of non-intrinsically safe equipment or tools Section 11: Hot Work Permit Procedures Employees and/or contractor’s personnel shall completely fill out and sign the entire JSA/Hot Work Permit before commencing work. Employees and/or contractor’s personnel shall obtain Hot Work Permit approval from the Authorized Representative and/or site supervisor. Section 11: Hot Work Permit Procedures
The production or process equipment must be prepared and isolated in accordance with applicable Lockout/Tagout (LOTO), Confined Space, and fire safety procedures. See Geo Fossil Fuels, Tabula Rasa Energy, Perdure Petroleum Lockout/Tagout (LOTO) Program and Confined Space Entry Program for additional requirements The Hot Work Permit must be reviewed with all employees and/or contractor’s personnel involved in the work and approval process. The Authorized Representative and/or site supervisors shall physically review the area and its conditions and designate precautions to be followed in granting authorization to proceed. Such precautions shall be included on the JSA/Hot Work Permit. For welding, applicable welder’s qualifications must be met. Section 11: Hot Work Permit Procedures – Preparation
The area where the Hot Work is to be performed shall be made fire safe. If the object upon which Hot Work is to be performed cannot be readily moved, all movable fire hazards in the vicinity shall be relocated to a safe place. If the neither the object on which Hot Work is being performed, or the fire hazards cannot be removed, then physical guards shall be used to separate the heat/sparks/slag and the flammable or combustible material. Section 11: Hot Work Permit Procedures – Preparation
The following additional precautions shall be taken where applicable:
Where combustible materials such as paper clippings, wood shavings, or textile fibers are on the floor, the floor shall be swept clean for a radius of 35 feet.
Combustible floors shall be kept wet, covered with damp sand, or protected by fire-resistant shields.
Where floors have been wet down, employees operating arc welding or cutting equipment shall be protected from possible shock.
Suitable fire extinguishing equipment shall be maintained in a state of readiness for instant use. Section 11: Hot Work Permit Procedures - Prohibitions
Hot Work shall not be permitted in the following areas:
areas not authorized by management;
buildings with sprinkler systems when such protection is impaired;
in or on vessels, tanks and lines that may have flammable or explosive gases, liquids, vapors or dusts, or are improperly prepared, and
areas within 35 feet of storage of large quantities of exposed combustible material such as bulk Sulphur, baled paper or cotton, etc.
Where practicable, all combustibles shall be relocated at least 35 feet from the work area.
Where relocation is impractical, combustibles shall be protected with flameproof covers or otherwise shielded with welding curtains or metal guards. Section 11: Hot Work Permit Procedures – Precautions
When Hot Work is to be done near walls, partitions, ceiling or roof of combustible construction, fire resistant shields shall be used to prevent ignition. If Hot Work is to be done on a metal wall, partition, ceiling or roof, precautions shall be taken to prevent ignition of combustibles on the other side, due to conduction or radiation.
If combustibles are not relocated, a Fire Watch shall be placed on the opposite side of the work. Hot Work shall not be performed:
on a metal wall, partition, ceiling or roof having a combustible covering or on combustible walls or partitions of combustible sandwich type panel construction.
on pipes or other metal in contact with combustible walls, partitions, ceilings or roofs if the work is close enough to cause ignition by conduction. Section 11: Hot Work Permit Procedures – Containers and Connections Hot Work shall not be performed on used drums, barrels, tanks, or other containers until they have been cleaned so thoroughly as to;
make absolutely certain that there are no flammable materials, or
substances such as greasers, tars, acids, or other materials,
which when subjected to heat might produce flammable or toxic vapors. Any pipelines 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. Section 11: Hot Work Permit Procedures – Welding Procedures
When arc or gas welding are suspended, the following procedures shall apply:
All electrodes shall be removed from the holders, and
the holders carefully located so that accidental contact cannot occur, and
the machine shall be disconnected from the power source.
The torch valves shall be closed, and
the gas supply to the torch positively shut off at some point outside the confined area.
Where practicable, the torch and hose shall also be removed from the Confined Space. Section 11: Hot Work Permit Procedures – Welding
A welder or helper working on platforms, scaffolds or runways shall be protected against falling through the use of railings, safety belts, lifelines, or some other equally effective safeguards. Welders shall place welding cable and other equipment so that it is clear of passageways, ladders and stairways. Welding equipment must be inspected for the following:
cracks, splits or loose connections in welding leads;
leaks in connections to oxygen or acetylene bottles, hoses and valves; and
installation of back flow valves. Section 11: Hot Work Permit Procedures – Fire Watch
An employee (or contractor) shall be designated to act as a Fire Watch whenever welding or cutting is performed in locations where the following conditions exist: combustible material in building construction or contents, closer than 35 feet to the point of operations; combustibles more than 35 feet away but easily ignited by sparks; wall or floor openings within a 35-foot radius expose combustible materials in adjacent areas, including concealed spaces in walls or floors; or combustible materials adjacent to the opposite side of metal partitions, walls, ceilings, or roofs and likely to be ignited by conduction or radiation. The Fire Watcher shall have proper fire extinguishing equipment and safety equipment and shall be trained in its use. Section 11: Hot Work Permit Procedures – Air Monitoring
Periodic checks of work in progress will be made with an explosimeter/4 gas meter. The job will be shut down if combustible gases are found. Work will not be allowed to continue until the situation is corrected and a new JSA/Hot Work Permit has been issued. Work areas and areas adjacent to the work areas will be inspected immediately after the completion of work to ensure no sparks have spread. The Fire Watch will remain on duty for 30 minutes after completion of work to ensure no fire or smoldering combustibles remain. Section 11: Hot Work Permit Procedures – Permit Requirements A pre-job meeting must be conducted to communicate safety and health precautions to employees and/or contractors’ personnel performing the work.
The employees and/or contractors’ personnel performing the work must sign the permit. Section 11: Hot Work Permit Procedures – Permit Requirements
The JSA/Hot Work Permit must include: date(s) for the authorized Hot Work; identification of the object on which Hot Work is to be performed; Section 11: Hot Work Permit Procedures – Permit Requirements
Documentation that fire prevention and protection requirements are met prior to the commencement of the Hot Work operations; approval signatures; and remain on site until the completion of Hot Work operations. Section 11: Hot Work – Responsibilities Management
Ensure the safe usage of cutting and welding equipment on its property. Establish areas for cutting and welding at plant and yard facilities, and establish procedures for cutting and welding in other areas, based on fire potentials. Designate an individual responsible for authorizing cutting and welding operations in areas not specifically designed for such processes. Insist that cutters or welders and their supervisors are suitably trained in the safe operation of their equipment and the safe use of the Hot Work Permit process. Provide employees and/or contractors’ personnel with information concerning flammable materials or hazardous conditions. Section 11: Hot Work – Responsibilities Supervisors
Verify that Hot Work Permit procedures are properly followed and completed. Sign as the Authorized Representative, and/or obtain proper signatures on the permit. Warn other employees and/or contractors’ personnel in the vicinity not to perform operations which would create a hazard within the Hot Work area. Stop work if a change occurs that can create an unsafe condition. Inspect the work area after the work is complete. Require the safe handling of cutting or welding equipment and safe use of the cutting or welding process. Determine whether combustible materials are present or likely to be present in the work location. Protect combustibles from ignitions by following the fire prevention and protection requirements listed in Permit Procedures. Section 11: Hot Work – Responsibilities Fire Watch The Fire Watch shall:
have fire extinguishing equipment and shall be trained in its use;
be familiar with procedures for sounding an alarm in the event of a fire;
watch for fires in all exposed areas and only extinguish them within their scope of training and equipment available (incipient stage fires);
not perform any other duties while "watching" for fires;
Stop the work if necessary and alert all employees and/or contractor’s of the potential hazards, and
Maintain a fire watch for at least 30 minutes after completion of welding or cutting operations to detect and extinguish possible smoldering fires. Section 11: Hot Work – Responsibilities Employees and Contractors
The employee(s) performing the work requiring the Hot Work Permit are responsible for: fully completing and signing the permit and coordinating Hot Work with his or her supervisor; complying with all Hot Work procedures and precautions, and stopping work if a hazardous condition develops. Contractors shall: Ensure that their personnel are aware of Company Hot Work Procedures, the contents of this section and applicable local, state, and federal laws and regulations. Ensure that their personnel are trained and qualified to perform welding, cutting or other Hot Work. Conduct their own Hot Work permitting, and/or participate in the Company’s Hot Work Program. Maintain a permanent record of personnel used which shows compliance with applicable federal, state or local laws and regulations for the type of work being performed (e.g., pipeline, pressured vessels). Questions and requests for forms can be submitted to the HSE Director.
Thank you! 18. Hydrogen Sulfide (H2S) Safety
Approved: Ronald T. Evans, CEO Document number: 01-2019 Revision No: 1 Revised: 08/08/2019
CONTENTS Section Topic Page 1.0 Purpose / Scope Page 3 2.0 Applicability Page 3 3.0 Hydrogen Sulfide Policy Page 3 4.0 Responsibilities Page 3 5.0 Hazard Control Page 4 6.0 Contractors Page 5 7.0 Hydrogen Sulfide Technical Data Page 5 8.0 Hydrogen Sulfide Measurements Page 10 9.0 Hydrogen Sulfide Monitors Page 11 10.0 Respiratory Protection Page 15 11.0 Hydrogen Sulfide Warning Devices Page 18 12.0 Hydrogen Sulfide Emergency Page 19 13.0 Contingency Plans Page 20 14.0 Drilling / Well Service / Workover Operations Page 22 15.0 General H2S Training Page 25 16.0 Relationship to Contractual Agreements Page 27 17.0 Relevant Company Programs Page 28 18.0 Document Management Page 28
Appendix A: OSHA Guidance / Letters (i.e. Clarifying H2S Tank Gauging Operations) Appendix B: National Institute for Occupational Safety and Health; H2S Data Sheet from NIOSH Pocket Guide to Chemical Hazards Appendix C: Representative Material Safety Data Sheet; Hydrogen Sulfide (H2S) Appendix D: State & Federal H2S Regulatory References: Texas Statewide Rule 36; Oil, Gas, or Geothermal Resource Operation in Hydrogen Sulfide Areas New Mexico, NMAC 19.15.11; Hydrogen Sulfide Gas (Hydrogen Sulfide) Oklahoma Rule 165:10-3-16; Operation in Hydrogen Sulfide Areas Wyoming, Rules and Regulations for Oil and Gas Well Drilling, Chapter 9; Hydrogen Sulfide Gas 18. Hydrogen Sulfide (H2S) Safety Revised: 08/08/2019
Mississippi Statewide Rule 66, Operations Involving Hydrogen Sulfide BLM Onshore Oil & Gas Order No.6; Hydrogen Sulfide Operations Bureau of Safety and Environmental Enforcement (BSEE), 30 CFR 250.490, 250.504, 250.604 & 250.807; Hydrogen Sulfide
Industry References: API RP49; Recommended Practice for Drilling and Well Servicing Operations Involving Hydrogen Sulfide API RP54; Recommended Practice for Occupational Safety for Oil and Gas Well Drilling and Servicing Operations API RP55; Recommended Practices for Oil and Gas Producing and Gas Processing Plant Operations Involving Hydrogen Sulfide API RP68; Recommended Practice for Oil and Gas Well Servicing and Workover Operations Involving Hydrogen Sulfide
2 of 60
18. Hydrogen Sulfide (H2S) Safety Revised: 08/08/2019
1. PURPOSE / SCOPE
1.1. The Hydrogen Sulfide (H2S) Safety Policy establishes the expectations, conditions and procedures applicable to protecting employees from exposure to the harmful health effects of H2S gas. The H2S Safety Policy outlines how to protect personnel from recognized hazards associated with working on equipment or in areas where the release of H2S could cause injury, illness or death.
1.2. Hydrogen Sulfide (H2S) gas is a hazard encountered in oil and gas exploration and production operations. The concentration levels of H2S gas associated with these operations can vary substantially and are dependent primarily on the quantity of H2S in reservoir formations, the age of producing fields and the type and extent of secondary or tertiary recovery activities.
2. APPLICABILITY
2.1. The H2S Safety Policy applies to all Geo Fossil Fuel, Tabula Rasa and Perdure Petroleum (Company) operated facilities / locations where employees could be exposed to atmospheric concentrations of H2S in excess of 10 parts per million (PPM).
2.2. Potential hazards identified outside the guidelines of the H2S Safety Policy shall be referred to the local safety representative, or the Director - HSE. The Area/Location Supervisor is responsible for securing the work area until the potential hazard can either be eliminated or safely managed.
3. HYDROGEN SULFIDE (H2S) POLICY
3.1. Employees that work in areas where exposure to H2S may exceed 10 PPM in the air shall conduct work in accordance with this H2S Safety Policy. Activities beyond normal operations (commissioning new facilities, tie-ins, tank or compressor overhauls, flowline repairs, confined space entry, etc.) in known or suspected H2S areas will be reviewed using the GFF/Tabula Rasa/Perdure SAFE WORK PERMIT/JSA (Job Safety Analysis) Form prior to the initiation of work so that appropriate operational plans can be developed and reviewed, and operating and safety equipment can be secured, inspected and approved for work.
4. RESPONSIBILITIES 4.1. Employees - Employees are responsible for being familiar with the safe work practices identified in the H2S Safety Policy and applying it to their work site. Employees must be able to recognize the potential health hazards associated with working in areas of H2S. Only employees who are trained in accordance with the requirements of the H2S Safety Policy and the Respiratory Protection Program may work in areas where H2S is present.
3 of 60
18. Hydrogen Sulfide (H2S) Safety Revised: 08/08/2019
4.2. Area/Location Supervisors/Person in Charge (PIC) – Area/Location Supervisors/PIC are responsible for assuring compliance with the H2S Safety Policy. This includes:
A. Ensuring that employees are trained in the H2S Safety Policy and that those trained maintain their understanding and receive periodic refresher training;
B. Verifying that contractors are H2S trained; (Contractors shall be required to provide proof that their employees are trained per section 6.4 below. Contractors are subject to onsite verification via a training certification card.) C. Ensuring that areas and equipment are surveyed and properly labeled relative to the presence of H2S; D. Reporting any implementation problems to their local safety representative.
4.3. Senior Vice President of Operations and Operations Management – Will implement the H2S Safety Policy, develop site-specific applications, annually review these procedures, and monitor its application to assure compliance.
4.4 Director - HSE is responsible for developing and revising the H2S Safety Policy in consultation with Operations Management and recordkeeping. 5. HAZARD CONTROL Hazard control is: 1) the use of engineering controls, 2) the application administrative controls and 3) the assignment of personal protective equipment (PPE). The priority or preference of use is in exactly this order.
5.1. Engineering controls are those practices that can be implemented to reduce or eliminate the hazard through the physical change in the work environment. Engineering control examples may include the use of mechanical or electronic gauging of production tanks, venting to sales line rather than to atmosphere, the use of vapor recovery units at operating facilities and the use of chemical scavengers to reduce or minimize the level of H2S in the production stream or in a temporary open system operation or flow-back. 5.2. Administrative procedures are the use of policies, work practices and employee training to reduce exposure to the hazard. Administrative procedures include allowing only personnel trained in H2S safety to work at H2S locations, survey for H2S or use fixed or personal monitoring devices. Includes the GFF/Tabula Rasa/Perdure SAFE WORK PERMIT/JSA) Form. A. A key individual should be assigned to monitor arrivals and departures at locations where multiple employees or contractors are working, and to
4 of 60
18. Hydrogen Sulfide (H2S) Safety Revised: 08/08/2019
advise new arrivals of H2S condition status and requirements for safe work prior to their release to perform work onsite.
5.3. PPE are barriers that protect the employee or contractor from the hazard. PPE controls use personal protective equipment to protect employees from hazards. PPE should be considered a last line of defense against injury and not the means for eliminating the hazard. PPE controls include the use of respiratory equipment for protection from H2S.
6. CONTRACTORS 6.1. Whenever contractors are to be engaged in work activities at Company locations, the Area/Location Supervisor or PIC will notify the contractor where atmospheric concentrations of H2S could exceed 10 PPM.
6.2. Contractors are responsible for performing their work in compliance with applicable state and federal regulations and industry recommended practices involving H2S environments.
6.3. Contractors are responsible for training their personnel in H2S safe work practices. The contractor shall provide verification of H2S training directly to Perdure or Tabula Rasa, or through a third-party service such as PEC/Veriforce. Contractor employees are subject to the requirement to show verification of training via a training certification card.
6.4. Contract personnel are required to furnish their own H2S safety equipment which may include respiratory protection, monitoring or ventilation equipment and provisions for emergency rescue. 6.5. Any issues will be discussed and resolved prior to commencement of the work. The contractor will provide and use their own JSA to perform hazard assessment and mitigation. If the contractor does not have a JSA form, then the GFF/Tabula Rasa/Perdure Petroleum JSA Form will need to be completed with the Area/Location Supervisor/PIC present.
7. H2S TECHNICAL DATA
7.1. H2S General Information
A. H2S is an extremely toxic, highly flammable, colorless gas which may be encountered in exploration, production and processing of natural gas, high-sulfur-content crude oil, crude oil fractions, associated gas and produced water.
B. H2S is formed by the decomposition of organic animal or vegetable materials by bacteria. H2S is found in oil and gas production, sewers, cesspools, stagnant water such as found in swamps and is produced in a variety of industrial and biological processes.
5 of 60
18. Hydrogen Sulfide (H2S) Safety Revised: 08/08/2019
C. H2S is referred to in the petroleum industry by a variety of names such as: 1. Hydrogen Sulfide; 2. Sour Crude; 3. Sour Gas; 4. Rotten-Egg; or 5. Swamp Gas.
7.2. Physical and Chemical Properties of H2S
Chemical formula: H2S Density (compared to air = 1.0): 1.2 (gas @ 15°C, 1 atm) Auto-ignition temperature: 500°F (260°C) Flammable range in air: 4 to 44% (by volume in air) Appearance of gas: Colorless Solubility in water (fresh or salt): Highly soluble Solubility in oil: Highly soluble Odor: "Rotten eggs" (at low concentrations) Odor threshold: 0.13 ppm* Olfactory fatigue level: 100 ppm* (may vary) (*parts per million in air)
7.3. H2S Physical Characteristics
A. H2S refers to either the gaseous or liquid form of the compound. Under atmospheric conditions it is a highly flammable and colorless gas. Typically called sour gas, H2S is soluble in water, crude oil, or petroleum fractions, and is highly corrosive. The gas can cause severe stress cracking of steel and other metals. H2S burns with a blue flame to form sulfur dioxide (SO2) which is also a toxic gas. H2S has a density 1.2 times greater than that of air and tends to settle in low lying areas. H2S is easily dispersed by wind movements or air currents.
SO2 is a toxic, heavier than air, colorless byproduct of combustion of H2S. SO2 has a pungent odor and the OSHA PEL (permissible exposure limit) is a TWA (time weighted average) of 5 PPM.
B. The concentration of H2S can be measured or expressed in two ways:
1. Parts per million (PPM) of H2S in liquid, by weight ratio; or
2. Parts per million (PPM) of H2S in air, by volume ratio.
6 of 60
18. Hydrogen Sulfide (H2S) Safety Revised: 08/08/2019
NOTE: While both methods of measurement are utilized within Company operations, there is a significant difference between a H2S concentration value in air and that in liquid. The actual concentration measured in air by volume ratio is usually much higher and can be 10 to 100 times higher than the same value measured in liquid by weight ratio. For example, crude oil being discharged into a storage tank may contain only 70 PPM H2S in the liquid by weight. However, the concentration of H2S in the tank vapor space above the crude oil could exceed 7000 PPM H2S by volume. Unless otherwise specified, all discussions in the H2S Safety Policy refer to H2S concentrations based on PPM in air, by volume ratio.
7.4. Flammability
A. H2S is a highly flammable gas, forming flammable mixtures with air over a very wide range of 4% to 44% by volume. H2S's flammable range is nearly seven times greater than that of gasoline. The gas has an auto ignition temperature of 500°F (260°C). Also, being heavier than air, H2S can migrate a considerable distance at low elevations to a source of ignition and flash. Ignition sources should be promptly extinguished or deenergized if a H2S emission is discovered or suspected. B. The range of flammable vapor or gas air mixture between the upper and lower flammable limit is known as the "flammable range", also frequently referred to as the "explosive range".
7.5. Hydrogen Sulfide Exposure Effects
A. H2S is extremely toxic at relatively low concentrations. Sudden, short term exposure to H2S at concentrations greater than 600 PPM can cause death within minutes. High concentrations of H2S, especially those capable of causing physiological damage, cannot be detected by the sense of smell. Primary consideration of H2S in the work environment should be placed on the potential for sudden, short-term, excessive exposures and related acute effects.
B. The effects associated with H2S exposure are primarily determined by the concentration of the gas encountered in the worker's breathing zone. Variation in the length of exposure and individual susceptibility are other important determinants in the type of exposure effects likely to occur. Exposure effects at various concentrations of H2S are summarized in the following table.
7 of 60
18. Hydrogen Sulfide (H2S) Safety Revised: 08/08/2019
7.6. Toxic Effects of H2S at Various Concentrations
The symptoms may vary individually according to length of exposure and the victim's physical condition. These symptoms may develop slowly over a period of hours or may develop within a matter of minutes or seconds depending on the concentration of H2S.
The principal health hazard of H2S is death by inhalation. In concentrations above 300 ppm H2S may result in death caused by respiratory paralysis. H2S is a poison gas that in sufficient concentrations shuts down the respiratory system (stops the breathing process). Once this happens the only way to revive victims is to start their breathing again by administering artificial respiration. CPR may also be required if the heart has stopped.
H2S is irritating to the skin; although it is not absorbed through the skin it does form a sulfuric acid solution when combined with moisture such as perspiration or the moisture present on the eyes and in the respiratory tract.
8 of 60
18. Hydrogen Sulfide (H2S) Safety Revised: 08/08/2019
IF EYE EXPOSURE OCCURS: FLUSH THE EYES WITH CLEAR RUNNING WATER FOR 15 MINUTES, FORCING THE EYELIDS OPEN IF NECESSARY, THEN SEEK MEDICAL ATTENTION.
FOR SKIN EXPOSURE: REMOVE CONTAMINATED CLOTHING, RINSE SKIN THOROUGHLY. WASH CLOTHES BEFORE WEARING AGAIN.
7.7. H2S Concentration Conversion Chart:
PPM Percent 1 PPM .0001% which is 1/10,000 of 1% 10 PPM .001 % which is 1/1,000 of 1% 100 PPM .01 % which is 1/100 of 1% 1,000 PPM .1% which is 1/10 of 1% 10,000 PPM 1.0% 100,000 PPM 10%
9 of 60
18. Hydrogen Sulfide (H2S) Safety Revised:
7.8. H2S Exposure Standards/Exposure Limits The US Occupational Safety and Health Administration (OSHA) along with the National Institute for Occupational Safety and Health (NIOSH) and the American Conference of Governmental and Industrial Hygienists (ACGIH) set standards which the oil and gas industry follows to protect employee safety and health. A. OSHA has a number of conflicting exposure standards for H2S, some of which are dependent on qualifying factors. Although the general industry limits are higher, OSHA sets a limit of a time weighted average (TWA) of 10 PPM for construction and shipyard workers. These limits combined with NIOSH and ACGIH recommendations constitute the basis for our exposure limits. 1. TWA - Time Weighted Average: An employee's average airborne exposure in any 8-hour work shift of a 40-hour work week which shall not exceed: 10 ppm per ACGIH 2009 standards, NIOSH recommends a 10 ppm limit of 10 minutes. 2. STEL - Short-Term Exposure Level: An employee's 15- minute time weighted average exposure which shall not be exceeded at any time during a work day: 15 ppm per ACGIH 2009 standards. 3. IDLH - Immediately Dangerous to Life or Health; concentration in air: 100 ppm per NIOSH standards.
B. The OSHA H2S exposure limits are based primarily on the irritant effects of the gas. These limits are designed to protect personnel from discomfort. They are not based on the more important concerns regarding the potentially disabling or lethal characteristics of H2S at higher concentrations, which are the basis of ACGIH and NIOSH standards and limits.
8. H2S MEASUREMENTS
Surveys to determine H2S concentration levels are to be made at Company locations. H2S measurements for safety and respiratory protection purposes are to be conducted either every two (2) years, or as processes change or conditions warrant at field locations where H2S is known or suspected. For new production, H2S measurements are to be conducted at the onset of startup operations. Area/Location Supervisors/PIC are responsible for ensuring that all Company operated facilities and locations have been
10 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
adequately evaluated for H2S gas or it's potential. If there is any question or doubt concerning actual H2S concentration levels at any Company operated facility or location, the local HSE representative or Director – HSE should be contacted. H2S measurement schedules for operational or equipment maintenance purposes is not provided in this policy as those measurements will be a facility-specific consideration.
8.1. Measurement Procedures
H2S measurements for safety and health/exposure purposes are to be conducted or coordinated by the local safety representative in compliance with state and federal regulations and in accordance with recognized standards and industry accepted practices. H2S measurements shall be made on the basis of: Tutwiler test, laboratory gas chromatograph results, the use of colorimetric detector tubes or by the use of electronic detection devices.
8.2. Sample Sites A. At production and produced water tanks, measurements are to be taken level with the thief hatch. B. At gas wells, production or processing facilities, plants and offshore platforms, gas samples are to be taken at representative locations within the system.
9. H2S MONITORS
H2S monitors (personal, portable or fixed) are to be utilized in Company drilling, completion, production, well servicing, workover and plant operations where atmospheric concentrations of H2S could exceed 10 PPM. Area/Location Supervisors/PIC are responsible for assuring that H2S monitoring equipment is available to protect employees involved in H2S operations. The Director - HSE is responsible for recommending appropriate H2S monitoring equipment to be utilized in Company operations.
Company employees are responsible for utilizing H2S monitoring equipment provided in accordance with the H2S Safety Policy requirements and training received.
9.1. Personal Monitors A. Company employees whose work responsibilities include drilling, completion, production, pipeline, construction, well servicing, workover and plant operations, where atmospheric concentrations
11 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
of H2S could exceed 10 PPM, are to be provided H2S personal monitors. 1. Personal monitors are designed to alert the wearer when the H2S concentration level reaches 10 PPM or greater.
B. Company employees assigned H2S personal monitors must: 1. Wear personal monitors on the collar, breast pocket or shirt front outside of all clothing for the complete workday at Company operated facilities and locations where atmospheric concentrations of H2S could exceed 10 PPM. When working under respiratory protection, the wearing of personal monitors is optional. 2. Check personal monitors daily or before each use to ensure that they are operating properly in accordance with monitor manufacturer's recommendations. Monitors which do not perform properly in this "go/no-go" check are to be removed from service and repaired or replaced. 3. Calibrate or bump test personal monitors in accordance with monitor manufacturer's recommendations and procedures utilizing approved calibration kits. 4. Perform routine maintenance on personal monitors in accordance with monitor manufacturer's recommendations and procedures. All repairs are to be performed only by the manufacturer or an authorized distributor technician. C. Questions concerning personal monitor selection, operation, calibration, maintenance or repairs are to be directed to the local safety representative or the Director - HSE.
9.2. Portable Monitors A. Continuous reading portable monitors (such as 4-gas units) are to be available where atmospheric concentrations of H2S could exceed 10 PPM. These continuous reading portable monitors are to be used: 1. To survey suspect areas; 2. To find sources of leaks; 3. When lines, valves or vessels or wellheads are opened or vented; and
12 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
4. For confined space entry activities including maintenance and inspection conducted by trained/qualified contractors.
Confined spaces in field areas may include enclosures, oil and saltwater tanks, gun barrels, heaters, separators, treaters, well cellars, excavated areas around flow lines (bell holes), open pits, and open produced water storage tanks. For additional information, see the Confined Space Entry Program. Note: Employees shall not conduct confined space entry into any tanks, vessels, cellars, pits or excavations. B. Portable monitors are to be used in the following manner: 1. Prior to initiating work, the portable monitor is to be used to thoroughly check the complete work area. Monitors are to be used with a probe so entry into the suspect area can be limited. The emphasis on monitoring must be on low lying areas where H2S is prone to concentrate. If the suspect area must be entered to perform the initial check, then respiratory protection must be worn. 2. Once the initial check of the area has been completed, the portable monitor is to be placed in the immediate work area and used to check conditions for the duration of the work task. 3. If the work task requires workers to be more dispersed, then additional portable monitors are to be utilized. H2S can become isolated to small areas and the gas has been known to increase from a low concentration to a hazardous level within a distance of several feet. C. Company employees are to calibrate portable monitors in accordance with monitor manufacturer's recommendations and procedures utilizing approved calibration kits. D. Company employees are to perform routine maintenance on portable monitors in accordance with monitor manufacturer's recommendations and procedures. All repairs beyond routine maintenance are to be performed only by the manufacturer or an authorized distributor technician. E. Questions concerning portable monitor selection, operation, calibration, maintenance or repairs are to be directed to the local safety representative or the Director - HSE.
13 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
9.3. Fixed Monitors
Certain facilities may require the need for and use of fixed H2S monitoring systems. For example, fixed monitors might be appropriate for installation at high pressure or high volume H2S well sites. Fixed monitors might also be appropriate for use where Company operated facilities are in close proximity to public areas. For assistance in determining the need for fixed monitors, contact the local HSE representative or the Director - HSE. A. Company employees are to calibrate fixed monitors in accordance with monitor manufacturer's recommendations and procedures utilizing approved calibration kits and gasses. B. Company employees are to perform routine maintenance on fixed monitors in accordance with monitor manufacturer's recommendations and procedures. All repairs beyond routine maintenance are to be performed only by the manufacturer or an authorized distributor technician. C. Calibration, maintenance and repair of fixed monitors or systems may be conducted by an authorized vendor or distributor technician, at the discretion of the operations area management. D. Questions concerning fixed monitor selection, operation, calibration, maintenance or repairs are to be directed to the local safety representative or the Director - HSE.
9.4. Common Requirements for Monitors A. Monitors with a single alarm level are to be set at a maximum of 10 PPM. Where monitors with dual alarms are used, the high-level alarm should not exceed 20 PPM and the low-level alarm must not exceed 10 PPM. Monitor alarm levels are set by the manufacturer or an authorized distributor representative. Company employees are not to adjust preset monitor alarm levels. B. The operation, calibration, maintenance and repair of personal, portable and fixed monitors must follow the recommendations provided by the manufacturer. Monitor operating manuals and instruction guides are to be available at field offices for quick reference by Company employees. Questions regarding the operation, calibration, maintenance and repair of monitors are to be directed to the Director – HSE or the local HSE representative.
14 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
C. Monitors are to be stored in a clean dry place. Personal and portable monitors are to be carried in the interior of vehicles and not in tool boxes. Monitors are not to be left in direct sunlight or in extreme of heat or cold. Necessary precautions are to be taken with all types of monitors to ensure that the sensor head is protected, does not become clogged with dust or dirt and that it does not become saturated with water or petroleum products. D. Monitors are not to be placed in untreated gas lines, sample ports or in the vapor space above tanks to check the alarm on the equipment. Such practice can cause irreparable damage to the monitor sensor. Use calibration gas to “bump test” a monitor.
10. RESPIRATORY PROTECTION Respiratory protection equipment is to be provided for employees where atmospheric concentration of H2S could exceed 10 PPM. Area/Location Supervisors/PIC are responsible for assuring that respiratory protection equipment is available for routine and emergency use to protect employees involved in H2S operations. Respiratory protection equipment is to be readily available to employees. The Director – HSE is responsible for recommending appropriate respiratory protection to be used in Company operations involving H2S and for conducting or coordinating respiratory protection training for employees. Employees required to use respiratory protection equipment on a routine or emergency basis are to receive medical clearance and annual training to ensure the proper and safe use of such equipment. Additional information may be found in the GFF/Tabula Rasa/Perdure Petroleum Respiratory Protection Program.
Section 10.5 of the Respiratory Protection Program prohibits facial hair that extends between the face and facepiece seal of a respirator face mask, or that interferes with the valve function for employees that may wear, must wear or will wear an SCBA or air supplied respirator in performing regular duties or emergency response.
10.1. Respirator Specification Requirements A. Only National Institute for Occupational Safety and Health/Mine Safety Health Administration (NIOSH/MSHA) approved positive pressure self- contained breathing apparatus (SCBA) or positive
15 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
pressure airline units with an emergency egress bottle with an air supply of at least five (5) minutes duration are to be provided and used for working in H2S, or rescue. The use of canister-type gas masks or any other type of air purifying respirators in H2S environments shall not be permitted. B. Breathing air in SCBAs and airline respirators shall meet the specifications for Grade D breathing air. Suppliers of compressed breathing air must furnish written documentation that air meets Grade D specification. A copy of this documentation must be kept on file at each location where breathing air is used. C. Employees working in the field where SCBAs or airline respirators are not required will be issued an emergency escape pack with a 10-minute rated air bottle. These are to be used when an unexpected alarm occurs and for escape purposes only.
10.2. Respirator Medical Clearance Requirements Employees must be physically able to utilize a SCBA or airline unit if they are to be assigned to a work location involving H2S operations. Employees who may be required to wear respiratory protection equipment on a routine or emergency basis will complete a Respiratory Medical Questionnaire. A Company authorized physician shall determine if an employee is approved to wear a respirator based on that questionnaire or refer the employee to a physician for further evaluation.
10.3. Respirator Training Requirements Employees expected to wear respirators for routine or emergency use are to receive annual training to ensure the proper and safe use of respirators.
10.4. Respirator Use Requirements A. Known Exposure - Respiratory protection use is mandatory at facilities and locations where exposure to atmospheric concentrations of H2S exceed 10 PPM. Work tasks that may expose employees to known H2S atmospheres of 10 PPM or more include: 1. Gauging or sampling oil and produced water tanks; 2. Performing routine maintenance in buildings like Header Buildings;
16 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
3. Performing oil and gas line repair;
4. Entering a confined space; Note: Employees shall not conduct confined space entry into any tanks, vessels, cellars, pits or excavations. 5. Bleeding down well casings or purging vessels; 6. Well control operations; 7. Drilling, testing and completion operations; and 8. Well servicing and workover operations. Respiratory protection is required to be worn during any Company operation or at any Company operated facility or location where atmospheric concentrations of H2S are determined by monitoring, testing or alarm to exceed 10 PPM. B. Suspected Exposure – Respiratory protection use is mandatory where atmospheric concentration of H2S could exceed 10 PPM or where the concentration is unknown. Work tasks that may expose employees to unknown or suspected H2S atmospheric of 10 PPM or more include: 1. Opening vessels, flowlines, pipelines or manways on tanks, etc., where the known concentration of H2S in the process or production stream exceeds 10 PPM. 2. For confined space work when the atmospheric concentration of H2S has not yet been determined and entry is required to perform the initial check; Note: Employees shall not conduct confined space entry into any tanks, vessels, cellars, pits or excavations. 3. During emergency rescue where there is the slightest chance that the victim has been overcome by H2S; 4. When checking known or suspected leaks at Company operated locations, facilities and pipelines involved in H2S service; 5. When it is necessary to evacuate the work environment due to a sudden release of H2S; and
6. When conducting initial H2S surveys when concentrations are unknown.
17 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
C. When atmospheric or breathing zone concentration of H2S exceeds 10 PPM or an alarm sounds, the use of a standby person is required to reenter the area and/or conduct work. Tank gauging and other operations requiring open thief hatches on tanks require a standby person when the concentration of H2S is 100 PPM or greater measured level with the thief hatch. These locations will be marked with appropriate signage. The standby person is required at all times, including call outs, and must have positive pressure SCBA immediately available.
11. H2S WARNING DEVICES Warning devices in the form of signs and wind indicators must be conspicuously posted and installed at Company operated facilities and locations where atmospheric concentration of H2S could exceed 10 PPM. Area/Locations Supervisors are responsible for ensuring that adequate warning devices are posted and installed at Company locations involving H2S operations. The local safety representative or the Director - HSE is responsible for recommending the proper warning devices to be utilized at Company locations. 11.1. Warning Signs A. Warning signs stating "DANGER - POISONOUS GAS - HYDROGEN SULFIDE" must be conspicuously posted at the entrances to Company operated facilities and locations and in close proximity to tank batteries, production or processing facilities, saltwater disposal facilities, compressor stations, producing oil and gas wells, drilling, completion, workover and well servicing locations where atmospheric concentrations of H2S could exceed 10 PPM. B. The signs have a white background. The word "DANGER" is in white letters on a red oval background panel. The sign's wording is black letters on a white background.
18 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
11.2. Wind Indicators Windsocks, streamers or vanes are to be installed and maintained in close proximity to tank batteries, production, plant or processing facilities, salt water disposal facilities and compressor stations and at drilling, completion, workover and well servicing locations where atmospheric concentrations of H2S could exceed 10 PPM. A. Wind indicators are to be installed where wind movement IS NOT obstructed, and visibility is assured. B. Wind direction is to be noted by all employees prior to entering Company operated facilities and locations to perform work.
C. Employees are to remain upwind of the source of H2S for the duration of the work, whenever feasible.
D. In the event of a release of H2S or when a H2S monitor alarms, employees are to immediately move crosswind and upwind and away from the suspected source of H2S. Employees are only to return wearing appropriate respiratory protection equipment and accompanied by a standby with respiratory protection available.
12. H2S EMERGENCY
The following requirements must be followed in a H2S emergency to reduce the potential for exposure to employees. Emergency procedures are to be performed as follows:
12.1. When an H2S alarm sounds, all personnel in the area must immediately evacuate the area. Move crosswind and upwind of the alarm. Personnel should muster in the predetermined safe briefing area. Personnel must wear respiratory protection to return to the area. 12.2. Notification / Evacuation Notification and evacuation of other personnel may be required when an H2S alarm has occurred. The extent of the notification and evacuation will depend on the severity of the release. Notify all personnel in the vicinity to:
A. Vacate the area if there is any potential for H2S exposure and H2S exposure and proceed to the predetermined safe briefing area. B. Summon medical attention if needed. Give your specific location.
C. Notify your supervisor of the H2S alarm and any actions taken.
19 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
12.3. Rescue All emergency rescue attempts must be performed with positive pressure type SCBA or airline units with emergency egress bottle. Do not attempt rescue without the proper respiratory protection or the rescuer may become a victim. A. Notify emergency response services and your supervisor. B. Check pressure and don emergency respiratory protection equipment, making certain of a good seal on the facepiece. C. Remove the individual from the suspected area to a safe location upwind and away from the source of H2S emissions. D. Once removed from the area, open the individual’s airway, check for breathing. Begin mouth-to-mouth artificial respiration if the individual is not breathing. E. Check for pulse. Initiate CPR if circulation has stopped. F. Treat for shock. G. If emergency medical personnel cannot be summoned to the scene quickly, the individual should be taken to the nearest hospital. H. Continue mouth-to-mouth artificial respiration or CPR during transport. Once started, CPR should be continued until the individual recovers or until turned over to trained emergency service personnel.
12.4. All individuals reacting to H2S exposure, which includes showing signs of severe persistent irritation, faintness, sluggishness, eye pain, convulsions, nausea, vomiting, confusion or unconsciousness, are to receive medical attention and remain under observation until released by a physician.
13. CONTINGENCY PLANS Written contingency plans are required for each Company operation where the public could be exposed to potentially hazardous atmospheric concentrations of H2S. Contingency plans must meet the requirements of the applicable regulatory agencies.
20 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
Contingency plans provide an organized plan of action for alerting and protecting the public and are to be activated immediately upon the detection of an accidental release of H2S. Contingency plans shall include: A. Instructions and procedures for alerting the general public within the potential area of exposure and public safety personnel; B. Procedures for requesting assistance and for follow-up action to remove the public from an area of exposure; C. A call list containing phone numbers of: 1. Local supervisory personnel; 2. County Sheriff; 3. Department of Public Safety; 4. City Police; 5. Ambulance Service; 6. Hospital; 7. Fire Department; 8. Doctors; 9. Contractors for supplemental equipment; 10. Local State Regulatory Agency Office; 11. Local State Air Control Board; and 12. Other Public Agencies. D. A plat locating the Company facility and the location of private dwellings, residential areas and public facilities within the potential area of exposure; E. A list of names, addresses and phone numbers of residents within the potential area of exposure; F. A list of names, addresses and phone numbers of responsible parties for public facilities within the potential area of exposure; G. Provisions for advance briefing of the public within the potential area of exposure which include:
1. The hazards and characteristics of H2S; 2. The necessity for an emergency action plan;
21 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
3. The possible sources of H2S within the potential area of exposure; 4. Instructions for reporting a gas leak; 5. The manner in which the public will be notified of an emergency; and 6. Steps to be taken in case of an emergency. H. Additional support information which includes: 1. Location of evacuation routes and shelter-in-place provisions; 2. Location of safety and life support equipment; 3. Location of H2S containing facilities; 4. Location of nearby telephone or other means of communication; and 5. Special instructions for conditions at a particular installation such as local terrain and the effect of various weather conditions. I. Contingency plans are to be retained at the Company operated facility or field location which lends itself best to the activation of the plan. 1. Area/Location Supervisors/PIC are responsible for ensuring that the contingency plans are updated. 2. The local safety representative is responsible for assisting Area/Location Supervisors/PIC in developing contingency plans for Company operated facilities and locations.
14. DRILLING, WELL SERVICING AND WORKOVER OPERATIONS Drilling, well servicing and workover operations conducted at Company locations where work area concentrations of H2S (known or suspected) could exceed 10 PPM are to be conducted in compliance with applicable governmental regulations and in accordance with industry recommended practices. A GFF/Tabula Rasa/Perdure SAFE WORK PERMIT/JSA or equivalent shall be completed prior to each shift or tower.
14.1. Hydrogen Sulfide Safety Equipment for Drilling New Wells When drilling operations are conducted and atmospheric concentrations of H2S could exceed 10 PPM, the safety equipment required includes the following:
22 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
A. Safety trailer with breathing air cascade and manifold system (Minimum of 10 – 300 ft3 cylinders/4 manifolds); B. Airline (NIOSH approved airline hose/sufficient footage for location setup and complement of personnel); C. Air-supplied airline respirators with emergency escape bottles (Minimum of 5 NIOSH approved units – more may be required to accommodate all crewmembers); D. SCBA respirators: Minimum of 2 NIOSH approved units with 30- minute air supply; positioned at muster point.
E. H2S monitor (4 channel unit/4 sensors); one each on floor, at shale shaker, mud pits and in the cellar. F. Alarm system (Light @ 10 ppm / Siren @ 20 ppm);
G. Portable H2S monitor (Can be combined in a 4-gas instrument) H. Portable SO2 monitor (Can be combined in a 4-gas instrument)
I. "H2S Warning" signs (Minimum 2);
J. "H2S Condition" signs (Minimum 2); K. "Muster Area” or “Safety Briefing Area" signs (Minimum 2); L. Windsock (Minimum 2); - 1 is sufficient for servicing or workover M. Sample gas (sufficient quantity for daily testing of sensors); N. Flare gun/cartridges; O. First aid kit/stretcher; P. Hand portable fire extinguisher (Minimum 20# ABC); Q. Full-body harnesses/life lines (Minimum 2); and R. Portable combustible gas detector. (Can be combined in a 4-gas instrument) NOTE: Monitors are to be calibrated and sensors checked and tested in accordance with monitor manufacturers recommendations.
Drilling, (Operations) Management is responsible for ensuring that H2S safety equipment as described herein is available and in place, at a minimum of 1000 feet above the known or suspected H2S bearing zone, to protect personnel involved in H2S drilling operations.
23 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
14.2. H2S Equipment for Well Servicing/Workover When well servicing or workover operations are conducted and atmospheric concentrations of H2S could exceed 10 PPM, the safety equipment required includes the following: A. Safety trailer with breathing air cascade and manifold system (Minimum of 10 – 300 ft3 cylinders/4 manifolds); B. Airline (NIOSH approved airline hose/sufficient footage for location setup and complement of personnel); C. Air-supplied airline respirators with emergency escape bottles (Minimum of 3 NIOSH approved units – more may be required to accommodate all crewmembers); D. SCBA respirators: Minimum of 2 NIOSH approved units with 30 minute air supply; positioned at muster point
E. H2S monitor (unit/4 sensors); one four gas unit shall be kept as near the floor as practical, unless the rig is equipped with fixed monitors. F. Alarm system (Light @ 10 ppm / Siren @ 20 ppm);
G. Portable H2S monitor (Can be combined in a 4-gas instrument) H. Portable SO2 monitor (Can be combined in a 4-gas instrument)
I. "H2S Warning" signs (Minimum 2);
J. "H2S Condition" signs (Minimum 2); K. "Muster Area” or “Safety Briefing Area" signs (Minimum 2); L. Windsock - 1 is sufficient for servicing or workover M. Sample gas (sufficient quantity for daily testing of sensors); O. First aid kit; P. Hand portable fire extinguisher (Minimum 2 20# ABC); Q. Full-body harnesses/life lines (Minimum 2); and R. Portable combustible gas detector. (Can be combined in a 4-gas instrument) NOTE: Monitors are to be calibrated and sensors checked and tested in accordance with monitor manufacturers recommendations.
24 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
14.3. Personnel Training A. Training is required for all personnel involved in drilling, well servicing or workover operations where the atmospheric concentrations of H2S could exceed 10 PPM. B. Drilling, well servicing, workover (Operations) Management and the Drilling Supervisor/Person in Charge is responsible for verifying that all personnel involved in H2S operations receive H2S training.
C. H2S training is to be conducted or coordinated by the Drilling Supervisor/Person in Charge or Tool-Pusher in charge on location, unless it has been conducted prior to arrival. 14.4. Contingency Plans A. Written contingency plans are required for each Company operated drilling operation where the public, following an accidental release of H2S, could be exposed to potentially hazardous atmospheric concentrations of H2S. Such plans are to meet the requirements of applicable regulatory agencies. B. Supervisors are responsible for ensuring that the contingency plans are developed and maintained with HSE Department support. C. The local safety representative is responsible for assisting supervisors in developing contingency plans for drilling, well servicing or workover operations. D. Specific details regarding the components on contingency plans are included above in Section 13 of this program.
15. GENERAL H2S TRAINING 15.1. Frequency A. Initial Training – Employees shall be initially trained to ensure familiarity with the H2S Safety Policy prior to working in a H2S environment. Training is to be provided to employees whose work responsibilities involve operations where atmospheric concentrations of H2S could exceed 10 PPM. B. Retraining – Employees shall receive retraining whenever there is a change in:
25 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
1. Their job assignments; 2. Activities that imposes hazards for which an employee has not been previously trained;
3. The H2S Safety Policy or regulatory requirements; or 4. Retraining shall also be conducted whenever there re inadequacies in an employee’s knowledge or deviations from the H2S Safety Policy are observed. The retraining shall re-establish employee proficiency and shall introduce new or revised methods and procedures as necessary.
C. Refresher Training – Employees shall receive annual refresher training in the H2S Safety Policy in accordance with their assigned responsibilities. D. Certification – Company will certify that the training outlined in the H2S Safety Policy has been accomplished. The certification will contain the employee’s name and signature, the signature of the trainer, the dates of training and documentation of the employees’ understanding of the material.
15.2. Learning Objectives Upon completion of the lesson, participants will:
A. Understand the purpose and the function of the H2S Safety Policy;
B. Understand the various roles of all employees in the H2S Safety Policy; C. Understand the hazards, properties, characteristics and toxicity of H2S as well as associated safety precautions;
D. Know the symptoms of exposure to H2S;
E. Know the resources and concentrations of H2S or SO2 in the workplace; F. Know the procedures for testing areas suspected of being contaminated with H2S or SO2; G. Know the location, use and care of: 1. Windsocks and wind indicators; 2. Mechanical blowers;
26 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
3. Respiratory protection equipment;
4. Fixed and portable H2S detection equipment;
5. SO2 detection equipment; 6. Combustible gas detection equipment; 7. Resuscitation equipment and first aid supplies; 8. Portable fire extinguishers; and 9. Emergency alarm system. H. Know the specific locations in the workplace which require respiratory protection;
I. Know the meaning of H2S warning signs; J. Know emergency rescue and first aid/CPR procedures.
K. Know what is contained in a H2S Contingency Plan and how to address H2S emergencies. This includes understanding the specific emergency response procedures for the applicable contingency plan. L. Know the rig or facility layout details including prevailing winds and personnel evacuation routes; M. Know that the use of standby person is required for IDLH atmospheres; N. Know the materials that are appropriate for the rig and well equipment or production equipment and the effect of H2S on metal components; O. Know the drilling fluid treating plan and procedures; and P. Understand the applicable government rules and regulations affecting drilling, well servicing or production operations involving H2S.
16. RELATIONSHIP TO CONTRACTUAL AGREEEMENTS Nothing contained in this guidance document shall be construed as altering in any way the rights, duties and obligations contained in any applicable contract or master service agreement (“Contract”) between parties. Where a conflict arises between this guidance and the Contract (MSA), the language of the Contract shall be controlling.
27 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
17. RELEVANT COMPANY PROGRAMS The following Programs are referenced within the Hydrogen Sulfide Safety Policy.
• Respiratory Protection Program (HSE Policy Manual Appendix)
• Confined Space Program (HSE Policy Manual Appendix) Note: Employees shall not conduct confined space entry into any tanks, vessels, cellars, pits or excavations. • GFF/TABULA RASA/PERDURE SAFE WORK PERMIT/JSA
18. DOCUMENT MANAGEMENT
18.1. The retention of written records such as H2S survey records, inspections and audits shall be retained for the life of the facility.
For H2S surveys, a file with survey results is to be maintained by the Area/Location Supervisor or local safety representative with a copy to the Director _ HSE. This file is to include: A. The date of the survey; B. A description of the specific location surveyed; C. The surveyor test method utilized;
D. The H2S concentration level in ppm; and E. The name of the person conducting the survey.
18.2. Employee training records, including attendance sheets and exams, shall be retained by the Director - HSE.
28 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
APPENDIX A
OSHA Guidance / Letters
29 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
30 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
31 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
32 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
OSHA Interpretation – Guidance for Open Tank Gauging 1910.134 – Respiratory Protection > 06/11/1990 – Respirator rules as applied to open hatch gauging of sour crude oil storage tanks • Standard Interpretations - Table of Contents
• Standard Number: 1910.134
June 11, 1990 M. E. McAllister, Ph.D. Manager - Environmental, Safety & Regulatory Compliance TOTAL Minatome Corporation Post Office Box 4326 Houston, Texas 77210-4326 Dear Dr. McAllister: Thank you for your letter of April 2, regarding an interpretation of respirator rules as applied to open hatch gauging of sour crude oil storage tanks. I apologize for the delay in responding to your inquiry. As you indicated in your letter, the Occupational Safety and Health Administration (OSHA) has re-examined its position on the number of standby persons required when open hatch gauging of sour crude oil storage tanks is performed in atmospheres immediately dangerous to life and health (IDLH) when self-contained breathing apparatus is used for protection. OSHA has concluded that for each gauging operation one standby person with suitable rescue equipment is adequate. I appreciate the opportunity to clarify this matter for you. Sincerely, Patricia K. Clark Director Designate Directorate of Compliance Programs
* * * * Above in response to following correspondence * * * * April 2, 1990 Ms. Patricia K. Clark, Director Designate Directorate of Compliance Programs U. S. Department of Labor, Occupational Safety and Health Administration 200 Constitution Avenue, N.W. Washington, D.C. 20210
33 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
Re: Request for Interpretation of 29 C.F.R. 1910.134 as applied to Open Health Gauging of Sour Crude Oil Storage Tanks Dear Ms. Clark: In an April 5, 1989 correspondence from former director of the Directorate of Compliance Programs, Thomas J. Shepich, it was stated: "When self-contained breathing apparatus is used in the open hatch gauging of sour crude oil tanks, [29 CFR 1910.134 (g)(3)(i-vi)] applies whenever known or potential concentrations of hydrogen sulfide (H2S) at the hatch can reach or exceed levels which are immediately dangerous to life or health (IDLH). Under these circumstances, two or more standby persons must be present and equipped with the appropriate rescue equipment." It was brought to my attention that your office has rescinded the position on the number of standby persons required. The gauging operations would require one standby person with the appropriate rescue equipment. I am sure you can appreciate the financial impact to a corporation if Mr. Shepich's interpretation is the requirement. It is TOTAL Minatome Corporations intent to conduct our operations in a manner consistent with OSHA requirements and to provide for the safety of our employees. TOTAL Minatome Corporation respectfully requests a formal interpretation of the existing respirator rule as applied to open hatch gauging of sour crude oil storage tanks. If there are any questions or if further information is required, please call. Your expedient assistance would be appreciated. Very truly yours, Dr. M.E. McAllister, Ph.D. Manager - Environmental, Safety & Regulatory Compliance
(End of OSHA Interpretation)
34 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
APPENDIX B
National Institute for Occupational Safety and Health (NIOSH) NIOSH Pocket Guide to Chemical Hazards – Hydrogen Sulfide
35 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
36 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
APPENDIX C
Representative Material Safety Data Sheet
Hydrogen Sulfide (H2S)
37 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
38 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
39 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
40 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
41 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
42 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
43 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
44 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
45 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
46 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
47 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
48 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
APPENDIX D: STATE & FEDERAL H2S REGULATIONS
Texas Rule §3.36 Oil, Gas, or Geothermal Resource Operations in Hydrogen Sulfide Areas
49 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
Texas Administrative Code TITLE 16 – Economic Regulation PART 1 – Railroad Commission of Texas CHAPTER 3 – Oil & Gas Division RULE §3.36 – Oil, Gas or Geothermal Resource Operations in Hydrogen Sulfide Areas (a) Applicability. Each operator who conducts operations as described in paragraph (1) of this subsection shall be subject to this section and shall provide safeguards to protect the general public from the harmful effects of hydrogen sulfide. This section applies to both intentional and accidental releases of hydrogen sulfide. (1) Operations including drilling, working over, producing, injecting, gathering, processing, transporting, and storage of hydrocarbon fluids that are part of, or directly related to, field production, transportation, and handling of hydrocarbon fluids that contain gas in the system which has hydrogen sulfide as a constituent of the gas, to the extent as specified in subsection (c) of this section, general provisions. (2) This section shall not apply to: (A) operations involving processing oil, gas, or hydrocarbon fluids which are either an industrial modification or products from industrial modification, such as refining, petrochemical plants, or chemical plants; (B) operations involving gathering, storing, and transporting stabilized liquid hydrocarbons; (C) operations where the concentration of hydrogen sulfide in the system is less than 100 ppm. (b) Definitions. (1) Industrial modification--This term is used to identify those operations related to refining, petrochemical plants, and chemical plants. The term does not include field processing such as that performed by gasoline plants and their associated gathering systems. (2) Stabilized liquid hydrocarbon--The product of a production operation in which the entrained gaseous hydrocarbons have been removed to the degree that said liquid may be stored at atmospheric conditions. (3) Radius of exposure--That radius constructed with the point of escape as its starting point and its length calculated as provided for in subsection (c)(2) of this section. (4) Area of exposure--The area within a circle constructed with the point of escape as its center and the radius of exposure as its radius. (5) Public area--A dwelling, place of business, church, school, hospital, school bus stop, government building, a public road, all or any portion of a park, city, town, village, or other similar area that can expect to be populated.
50 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
(6) Public road--Any federal, state, county, or municipal street or road owned or maintained for public access or use. (7) Sulfide stress cracking--The cracking phenomenon which is the result of corrosive action of hydrogen sulfide on susceptible metals under stress. (8) Facility modification--Any change in the operation such as an increase in throughput, in excess of the designed capacity, or any change that would increase the radius of exposure. (9) Public infringement--This shall mean that a public area and/or a public road, or both, has been established within an area of exposure to the degree that such infringement would change the applicable provisions of this rule to those operations responsible for creating the area of exposure. (10) Potentially hazardous volume of hydrogen sulfide--A volume of hydrogen sulfide gas of such concentration that: (A) the 100 ppm radius of exposure is in excess of 50 feet and includes any part of a "public area" except a public road; or (B) the 500 ppm radius of exposure is greater than 50 feet and includes any part of a public road; or (C) the 100 ppm radius of exposure is greater than 3,000 feet. (11) Contingency plan--A written document that shall provide an organized plan of action for alerting and protecting the public within an area of exposure prior to an intentional release or following the accidental release of a potentially hazardous volume of hydrogen sulfide. (12) Reaction-type contingency plan--A preplanned, written procedure for alerting and protecting the public, within an area of exposure, where it is impossible or impractical to brief in advance all of the public that might possibly be within the area of exposure at the moment of an accidental release of a potentially hazardous volume of hydrogen sulfide. (A) ANSI--American National Standard Institute, 1430 Broadway, New York, New York 10018, Table I, Standard 253.1-1967. (B) API--American Petroleum Institute, 300 Corrigan Tower Building, Dallas, Texas 75201, Publication API RP-49, Publication API RP-14E, Sections 1.7(c), 2.1(c) 4.7. (C) ASTM--American Society for Testing and Materials, 1916 Race Street, Philadelphia, Pennsylvania 19103, Standard D-2385-66. (D) GPA--Gas Processors Association, 1812 First Place, Tulsa, Oklahoma 74120, Plant Operation Test Manual C-1, GPA Publication 2265-68. (E) NACE--National Association of Corrosion Engineers, P.O. Box 1499, Houston, Texas 77001, Standard MR-01-75. (F) DOT--Department of Transportation, Office of Pipeline Safety, 400 Seventh Street, S.W., Washington, D.C. 20590, Title 49, Code of Federal Regulations, Parts 192 and 195.
51 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
(G) OSHA--Occupational Safety and Health Administration, United States Department of Labor, 200 Constitution Avenue, NW, Washington D.C. 20270, Title 29, Code of Federal Regulations, Part 1910.145(c)(4)(i). (H) RRC--Railroad Commission of Texas, Gas Utilities Division, P.O. Drawer 12967, Capitol Station, Austin, Texas 78711, Gas Utilities Dockets 446 and 183. (c) General provisions. (1) Each operator shall determine the hydrogen sulfide concentration in the gaseous mixture in the operation or system. (A) Tests shall be made in accordance with standards as set by ASTM Standard D-2385-66, or GPA Plant Operation Test Manual C-1, GPA Publication 2265-68, or other methods approved by the commission. (B) Test of vapor accumulation in storage tanks may be made with industry accepted colorimetric tubes. (2) For all operations subject to this section, the radius of exposure shall be determined, except in the cases of storage tanks, by the following Pasquill-Gifford equations, or by other methods that have been approved by the commission. (A) For determining the location of the 100 ppm radius of exposure: x = [(1.589) (mole fraction H2 S)(Q)] to the power of (.6258). (B) For determining the location of the 500 ppm radius of exposure: x = [(0.4546) (mole fraction H2 S)(Q)] to the power of (.6258). Where x = radius of exposure in feet; Q = maximum volume determined to be available for escape in cubic feet per day; H 2 S = mole fraction of hydrogen sulfide in the gaseous mixture available for escape. (3) The volume used as the escape rate in determining the radius of exposure shall be that specified in subparagraph (A) - (E) of this paragraph, as applicable. (A) The maximum daily volume rate of gas containing hydrogen sulfide handled by that system element for which the radius of exposure is calculated. (B) For existing gas wells, the current adjusted open-flow rate, or the operator's estimate of the well's capacity to flow against zero back-pressure at the wellhead shall be used. (C) For new wells drilled in developed areas, the escape rate shall be determined by using the current adjusted open-flow rate of offset wells, or the field average current adjusted open-flow rate, whichever is larger. (D) The escape rate used in determining the radius of exposure shall be corrected to standard conditions of 14.65 pounds per square inch (psia) and 60 degrees Fahrenheit. (E) For intentional releases from pipelines and pressurized vessels, the operator's estimate of the volume and release rate based on the gas contained in the system elements to be de-pressured. (4) For the drilling of a well in an area where insufficient data exists to calculate a radius of exposure, but where hydrogen sulfide may be expected, then a 100 ppm radius of exposure equal to 3,000 feet shall be assumed. A lesser-assumed
52 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
radius may be considered upon written request setting out the justification for same. (5) Storage tank provision: storage tanks which are utilized as a part of a production operation, and which are operated at or near atmospheric pressure, and where the vapor accumulation has a hydrogen sulfide concentration in excess of 500 ppm, shall be subject to the following. (A) No determination of a radius of exposure shall be made for storage tanks as herein described. (B) A warning sign shall be posted on or within 50 feet of the facility to alert the general public of the potential danger. (C) Fencing as a security measure is required when storage tanks are located inside the limits of a townsite or city, or where conditions cause the storage tanks to be exposed to the public. (13) Definition of referenced organizations and publications (D) The warning and marker provision, paragraph (6)(A)(i), (ii), and (iv) of this subsection. (E) The certificate of compliance provision, subsection (d)(1) of this section. (6) All operators whose operations are subject to this section, and where the 100 ppm radius of exposure is in excess of 50 feet, shall be subject to the following. (A) Warning and marker provision. (i) For above-ground and fixed surface facilities, the operator shall post, where permitted by law, clearly visible warning signs on access roads or public streets, or roads which provide direct access to facilities located within the area of exposure. (ii) In populated areas such as cases of townsites and cities where the use of signs is not considered to be acceptable, then an alternative warning plan may be approved upon written request to the commission. (iii) For buried lines subject to this section, the operator shall comply with the following. (I) A marker sign shall be installed at public road crossings. (II) Marker signs shall be installed along the line, when it is located within a public area or along a public road, at intervals frequent enough in the judgment of the operator so as to provide warning to avoid the accidental rupturing of line by excavation. (III) The marker sign shall contain sufficient information to establish the ownership and existence of the line and shall indicate by the use of the words "Poison Gas" that a potential danger exists. Markers installed in compliance with the regulations of the federal Department of Transportation shall satisfy the requirements of this provision. Marker signs installed prior to the effective date of this section shall be acceptable provided they indicate the existence of a potential hazard.
53 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
(iv) In satisfying the sign requirement of clause (i) of this subparagraph, the following will be acceptable. (I) Sign of sufficient size to be readable at a reasonable distance from the facility. (II) New signs constructed to satisfy this section shall use the language of "Caution" and "Poison Gas" with a black and yellow color contrast. Colors shall satisfy Table I of American National Standard Institute Standard 253.1-1967. Signs installed to satisfy this section are to be compatible with the regulations of the federal Occupational Safety and Health Administration. (III) Existing signs installed prior to the effective date of this section will be acceptable if they indicate the existence of a potential hazard. (B) Security provision. (i) Unattended fixed surface facilities shall be protected from public access when located within 1/4 mile of a dwelling, place of business, hospital, school, church, government building, school bus stop, public park, town, city, village, or similarly populated area. This protection shall be provided by fencing and locking, or removal of pressure gauges and plugging of valve opening, or other similar means. For the purpose of this provision, surface pipeline shall not be considered as a fixed surface facility. (ii) For well sites, fencing as a security measure is required when a well is located inside the limits of a townsite or city, or where conditions cause the well to be exposed to the public. (iii) The fencing provision will be considered satisfied where the fencing structure is a deterrent to public access. (C) Materials and equipment provision. (i) For new construction or modification of facilities (including materials and equipment to be used in drilling and workover operations) completed or contemplated subsequent to the effective date of this section, the metal components shall be those metals which have been selected and manufactured so as to be resistant to hydrogen sulfide stress cracking under the operating conditions for which their use is intended, provided that they satisfy the requirements described in the latest editions of NACE Standard MR-01-75 and API RP-14E, sections 1.7(c), 2.1(c), 4.7. The handling and installation of materials and equipment used in hydrogen sulfide service are to be performed in such a manner so as not to induce susceptibility to sulfide stress cracking. Other materials which are non-susceptible to sulfide stress cracking, such as fiberglass and plastics, may be used in hydrogen sulfide service provided such materials have been manufactured and inspected in a manner which will satisfy the latest published, applicable industry standard, specifications, or recommended practices. (ii) Other materials and equipment (including materials and equipment used in drilling and workover operations) which are not included within the provision of clause (i) of this subparagraph may be used for hydrogen sulfide service provided:
54 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
(I) such materials and equipment are proved, as the result of advancements in technology or as the result of control and knowledge of operating conditions (such as temperature and moisture content), to be suitable for the use intended and where such usage is technologically acceptable as good engineering practice; and (II) the commission has approved the use of said materials and equipment for the specific uses after written application. (iii) Existing facilities (including materials in present common usage for drilling and workover operations in hydrogen sulfide areas) which are in operation prior to the effective date of this section, and where there has been no failure of existing equipment attributed to sulfide stress cracking, shall satisfy the requirements of this section. (iv) In the event of a failure of any element of an existing system as the result of hydrogen sulfide stress cracking, the compliance status of the system shall be determined by the commission after the operator has submitted to the commission a detailed written report on the failure. (7) All operations subject to subsection (a) of this section shall be subject to the additional control and equipment safety provision, paragraph (8) of this subsection, and the contingency plan provision, paragraph (9) of this subsection, if any of the following conditions apply: (A) the 100 ppm radius of exposure is in excess of 50 feet and includes any part of a "public area" except a public road; (B) the 500 ppm radius of exposure is greater than 50 feet and includes any part of a public road; (C) the 100 ppm radius of exposure is greater than 3,000 feet. (8) Control and equipment safety provision. Operators subject to this provision shall install safety devices and maintain them in an operable condition or shall establish safety procedures designed to prevent the undetected continuing escape of hydrogen sulfide. For intentional releases of a potentially hazardous volume of hydrogen sulfide gas, the gas must be flared unless permission to vent is obtained from the commission or its delegate. Venting will be allowed only upon a showing that the venting will not pose an unreasonable risk of harm to the public. (9) Contingency plan provision. (A) All operators whose operations are subject to this provision shall develop a written contingency plan complete with all requirements before hydrogen sulfide operations are begun. (B) The purpose of the contingency plan shall be to provide an organized plan of action for alerting and protecting the public prior to an intentional release, or following the accidental release of a potentially hazardous volume of hydrogen sulfide. (C) The contingency plan shall be activated prior to an intentional release, or immediately upon the detection of an accidental release of a potentially hazardous volume of hydrogen sulfide.
55 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
(D) Conditions that might exist in each area of exposure shall be considered when preparing a contingency plan. (E) The plan shall include instructions and procedures for alerting the general public and public safety personnel of the existence of an emergency. (F) The plan shall include procedures for requesting assistance and for follow- up action to remove the public from an area of exposure. (G) The plan shall include a call list which shall include the following as they may be applicable: (i) local supervisory personnel; (ii) county sheriff; (iii) Department of Public Safety; (iv) city police; (v) ambulance service; (vi) hospital; (vii) fire department; (viii) doctors; (ix) contractors for supplemental equipment; (x) district Railroad Commission office; (xi) the appropriate regional office of the Texas Commission on Environmental Quality or its successor agencies; (xii) other public agencies. (H) The plan shall include a plat detailing the area of exposure. The plat shall include the locations of private dwellings or residential areas, public facilities, such as schools, business locations, public roads, or other similar areas where the public might reasonably be expected within the area of exposure. (I) The plan shall include names and telephone numbers of residents within the area of exposure, except in cases where the reaction plan option has been approved by the commission in accordance with subparagraph (L) of this paragraph. (J) The plan shall include a list of the names and telephone numbers of the responsible parties for each of the possibly occupied public areas, such as schools, churches, businesses, or other public areas or facilities within the area of exposure. (K) The plan shall include provisions for advance briefing of the public within an area of exposure. Such advance briefing shall include the following elements: (i) the hazards and characteristics of hydrogen sulfide; (ii) the necessity for an emergency action plan; (iii) the possible sources of hydrogen sulfide within the area of exposure; (iv) instructions for reporting a gas leak; (v) the manner in which the public will be notified of an emergency; (vi) steps to be taken in case of an emergency. (L) In the event of a high density of population, or the case where the population density may be unpredictable, a reaction type of plan, in lieu of advance
56 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
briefing for public notification, will be acceptable. The reaction plan option must be approved by the commission. (M) The plan shall include additional support information, if applicable, such as: (i) location of evacuation routes; (ii) location of safety and life support equipment; (iii) location of hydrogen sulfide containing facilities; (iv) location of nearby telephones and/or other means of communication; and (v) special instructions for conditions at a particular installation such as local terrain and the effect of various weather conditions. (N) The Railroad Commission District Office shall be notified as follows if the contingency plan is activated: (i) 12 hours in advance of an intentional release or as soon as a decision is made to release if such decision could not reasonably have been made more than 12 hours prior to the release; (ii) immediately in the case of an accidental release; (iii) as soon as possible before or after an unplanned intentional release made in an emergency situation to prevent a possible uncontrolled release. (O) The retention of the contingency plan shall be as follows. (i) The plan shall be available for commission inspection at the location indicated on the certificate of compliance. (ii) The plan shall be retained at the location which lends itself best to activation of the plan. (P) In the event that, due to particular situations, a contingency plan cannot be developed consistent with the provisions of this paragraph, relating to the contingency plan, then the operator may develop an adjusted plan to fit the situation, and submit same with the certificate of compliance. Approval of the certificate of compliance so submitted will constitute approval of the contingency plan. (Q) The plan shall be kept updated to insure its current applicability. (10) Injection provision. (A) Injection of fluids containing hydrogen sulfide shall not be allowed under the conditions specified in this provision unless first approved by the commission after public hearing: (i) where injection fluid is a gaseous mixture, or would be a gaseous mixture in the event of a release to the atmosphere, and where the 100 ppm radius of exposure is in excess of 50 feet and includes any part of a public area except a public road; or, if the 500 ppm radius of exposure is in excess of 50 feet and includes any part of a public road; or if the 100 ppm radius of exposure is 3,000 feet or greater; (ii) where the hydrogen sulfide content of the gas or gaseous mixture to be injected has been increased by a processing plant operation.
57 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
(B) Each project involving the injection of gas or gaseous mixtures containing hydrogen sulfide which does not require a public hearing prior to receiving commission approval specified in this provision shall nevertheless be subject to the other provisions of this section to the extent that such provisions are applicable to such project. (11) In addition to any other requirements of this section, drilling and workover operations, and gasoline plant sites where the 100 ppm radius of exposure is 50 feet or greater shall be subject to the following. (A) Protective breathing equipment shall be maintained in two or more locations at the site. (B) Wind direction indicators shall be installed at strategic locations at or near the site and be readily visible from the site. (C) Automatic hydrogen sulfide detection and alarm equipment that will warn of the presence of hydrogen sulfide gas in concentrations that could be harmful shall be utilized at the site. (12) Drilling provision. Drilling and workover operations where the 100 ppm radius of exposure includes a public area or is 3,000 feet or greater shall be subject to the following additional provisions. (A) Protective breathing equipment shall be maintained at the well site and shall be sufficient to allow for well control operations. (B) The operator shall provide a method of igniting the gas in the event of an uncontrollable emergency. (C) The operator shall install a choke manifold, mud-gas separator, and flare line, and provide a suitable method for lighting the flare. (D) Secondary remote control of blowout prevention and choke equipment to be located away from the rig floor at a safe distance from the wellhead. (E) Drill stem testing of hydrogen sulfide zones is permitted only in daylight hours. (F) The Railroad Commission district office shall be notified of the intention to conduct a drill stem test of a formation containing hydrogen sulfide in sufficient concentration to meet the requirements of this provision. (G) A certificate of compliance shall be required on each well subject to this provision even if well is located on certificated lease. (H) Full compliance with all the requirements of this provision must be satisfied before the well is drilled to a depth that is within 1,000 feet of the hydrogen sulfide zone. Alternate depths may be approved in advance by the appropriate commission district office. (I) API Publication RP-49 is referenced as a suggested guideline for drilling and workover of wells subject to this provision. (J) Blowout preventers and well control systems shall be pressure tested at or near compliance depth or at depth of nearest bit change prior to reaching compliance depth. The appropriate Railroad Commission district office must be notified at least four hours prior to the test.
58 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
(13) Training requirement provision. (A) Each operator whose operations contain hydrogen sulfide in excess of 100 ppm shall train its employees working in the affected areas in hydrogen sulfide safety. (B) Each operator shall require all service companies working in affected areas to utilize only those service company personnel who have been trained in accordance with the provisions of subparagraphs (C) and (D) of this paragraph. Written certification to the operator by the service company that only those service company personnel who have been trained in accordance with the training requirement provision will be utilized in affected areas complies with this provision. For this provision, service company shall mean any company actually performing work at well sites, gasoline plant sites, or on pipelines, where such work could allow the escape of hydrogen sulfide gas. (C) The training of all personnel working in the affected areas shall include the following elements: (i) hazards and characteristics of hydrogen sulfide; (ii) safety precautions; (iii) operation of safety equipment and life support system. (D) On-site supervisory personnel shall be additionally trained in the following: (i) effect of hydrogen sulfide on metal components in the system; (ii) corrective action and shutdown procedures, and when drilling a well, blowout prevention, and well control procedures; (iii) must have full knowledge of the requirements of the contingency plan, when such plan is required. (E) Training schedules and course outlines shall be provided to the commission personnel upon request for the purpose of commission review to determine compliance with the provisions of subparagraphs (C) and (D) of this paragraph. (14) Accident notification. Operators shall immediately notify the appropriate Railroad Commission District Office of any accidental release of hydrogen sulfide gas of sufficient volume to present a hazard and of any hydrogen sulfide related accident. (d) Reports required. (1) Certificate of compliance provision. A certificate of compliance shall be submitted for operations subject to any provision of this section. The following shall apply to the certificate of compliance provision of the section. (A) The certificate of compliance shall certify that operator has complied or will comply with applicable provisions of this section. (B) The certificate of compliance shall be filed in triplicate in the commission district office where the operation is located.
59 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
(C) The certificate of compliance shall certify that existing operations subject to this section to be in compliance will be in compliance as specified in an attached schedule, or, for new or modified facilities, will be in compliance upon completion. (D) An approved certificate of compliance will permit an operator to perform all activities described in the certificate without additional filing of approval; provided that, consistent with subsection (c)(12)(G) of this section, a certificate of compliance will be required on each well subject to the provisions of subsection (c)(12)(G) of this section. (E) A new or amended certificate of compliance shall be required if there is a change in public exposure caused by public infringement of an existing radius of exposure resulting in a change in the applicable provisions of this section, not described by the existing certificate. The operator shall file the new or amended certificate within 30 days after such infringement. (F) A new or amended certificate of compliance shall be required if there is modification of an existing operation or facility which increases the radius of exposure in a public area, or results in a change in the applicable provisions of this section not described by the existing certificate. The operator shall file the new or amended certificate at least 30 days prior to initiating the operation or construction. (G) The operator shall file a certificate of compliance 30 days prior to commencement of a drilling or workover operation on wells where a certificate of compliance is required for that well by provisions of this section (wells drilled on noncertificated leases or wells with a 100 ppm radius of exposure greater than 3,000 feet). (H) In case of extenuating circumstances, an operator may file a certificate of compliance with an attached written explanation for those cases where waiver of 30-day prior filing is requested. In such cases, the approval of the certificate of compliance will constitute authority to proceed. (I) The certificate of compliance shall be prepared and executed by a party who, through training and experience, is qualified to make such certification. (J) The certificate of compliance will be in effect until conditions are altered in a manner that would require amending the "certificate." The operator shall notify the commission within 30 days following cessation or abandonment of operations in a certificated area. (K) The certificate of compliance required by the provisions of this order for an existing system are due in the district office as soon as is reasonably possible, and no later than September 1, 1976, and as applicable for new or modified operations. (L) A certificate of compliance may cover a single operation or multiple operations located in an area, a field, or a group of fields within a commission district. The description of the type of operation as indicated on the form must be sufficiently complete to the degree that it is obvious what element of an operation is to be covered by the certificate. All Railroad Commission identification numbers
60 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
for each element of the system must be shown on the certificate and must be identified as to the type of operation. (M) Certificates are nontransferable, and a new operator of a system or any acquired element of a system or operation shall be required to certificate that operation. Operator of a certificated system shall notify the commission in writing when the system or any operating part has been transferred to another operator. An amended certificate shall be required should any change occur that would add or delete a Railroad Commission identification number covered by the certificate. (N) Each operator shall maintain a current master list of all his operations for which a certificate of compliance is in effect and shall submit such list for inspection upon request by the commission. (2) Completion report provision.
(A) The operator shall report on the initial completion report for new oil or gas wells the hydrogen sulfide concentrations of the wellhead gas for all wells where the hydrogen sulfide concentration is equal to or exceeds 100 ppm. (B) The drilling of a well in an area which would require the submission of a certificate of compliance (Form H-9) shall have noted on the drilling application (Form W-1) that such certification has been filed. (3) Releases of, and accidents related to, hydrogen sulfide. The operator shall furnish a written report to the district office within ten days of any accidental release of hydrogen sulfide gas of sufficient volume to present a hazard and of any hydrogen sulfide related accident, whether it be from an accidental or intentional release. (e) Exception provision. Any application for exception to the provisions of this section should specify the provisions to which exception is requested, and set out in detail the basis on which the exception is to be requested. Source Note: The provisions of this §3.36 adopted January 1, 1976; amended to be effective September 1, 1976, 1 TexReg 1517; amended to be effective September 15, 1985, 10 TexReg 2069; amended to be effective April 7, 1995, 20 TexReg 2285; amended to be effective November 24, 2004, 29 TexReg 10728
(End of SWR 36)
New Mexico
61 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
NMAC 19.15.11 Hydrogen Sulfide Gas (Hydrogen Sulfide)
NEW MEXICO OIL CONSERVATION DIVISION Home: http://www.emnrd.state.nm.us/OCD/ Title 19 – Natural Resources and Wildlife Chapter 15 – Oil and Gas Rules: http://www.emnrd.state.nm.us/OCD/documents/SearchablePDFofOCDTitle1 9Chapter15created3-2-2012_updated_07-06-2015.pdf See Part 11 – Hydrogen Sulfide Gas
Oklahoma Rule 165:10-3-16 Operations in Hydrogen Sulfide Areas
OKLAHOMA CORPORATION COMMISSION Home: http://www.occeweb.com/index.html Title 165 – Corporation Commission Chapter 10 – Oil and Gas Conservation Code: http://www.occeweb.com/rules/CH10eff08-27-15searchable.pdf See Subchapter 3 – Drilling, Developing and Producing § 165:10-3-16 – Operation in hydrogen sulfide areas ______
62 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
Wyoming Rules and Regulations for Oil and Gas Well Drilling Chapter 9 Hydrogen Sulfide Gas WYOMING OIL AND GAS CONSERVATION COMMISSION Home: http://wogcc.state.wy.us/
STATE OF WYOMING OCCUPATIONAL HEALTH AND SAFETY RULES AND REGULATIONS FOR OIL AND GAS WELL DRILLING Rules: http://wyomingworkforce.org/_docs/osha/Oil-Drilling-Rules.pdf
See Chapter 9 – Hydrogen Sulfide (H2S) Gas
Mississippi Statewide Rule 66 Operations Involving Hydrogen Sulfide
MISSISSIPPI STATE OIL AND GAS BOARD Home: http://www.ogb.state.ms.us/Default.htm See Rule 66 – Operations Involving Hydrogen Sulfide Rulebook: http://www.ogb.state.ms.us/Rulebook.html ______Bureau of Land Management (BLM) Onshore Oil & Gas Order No.6 Hydrogen Sulfide Operations BUREAU OF LAND MANAGEMENT
Onshore Oil and Gas Order No. 6 – Hydrogen Sulfide Operations Order: http://www.blm.gov/wy/st/en/programs/energy/Oil_and_Gas/docs/onshore_order_ 6.html
63 of 64
18. Hydrogen Sulfide (H2S) Safety Revised:
BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT (BSEE) (Formerly Minerals Management Service) 30 CFR 250.490, .504, .604 & .807 Hydrogen Sulfide Home: http://www.bsee.gov/ 30 CFR 250 – Oil & Gas & Sulphur Operations in the Outer Continental Shelf Subpart D – Oil and Gas Drilling Operations §30 CFR 250.490 – Hydrogen sulfide http://www.gpo.gov/fdsys/pkg/CFR-2012-title30-vol2/pdf/CFR-2012-title30-vol2- sec250-490.pdf
Subpart E – Oil and Gas Well – Completion Operations §30 CFR 250.504 – Hydrogen sulfide http://www.gpo.gov/fdsys/pkg/CFR-2012-title30-vol2/pdf/CFR-2012-title30-vol2- sec250-504.pdf
Subpart F – Oil and Gas Well – Workover Operations §30 CFR 250.604 – Hydrogen sulfide http://www.gpo.gov/fdsys/pkg/CFR-2012-title30-vol2/pdf/CFR-2012-title30-vol2- sec250-604.pdf
Subpart H – Oil and Gas Production Safety Systems §30 CFR 250.808 – Hydrogen sulfide http://www.gpo.gov/fdsys/pkg/CFR-2012-title30-vol2/pdf/CFR-2012-title30-vol2- sec250-808.pdf
64 of 64
JSA / Safe Work Permit Carl Thunem, Director HSE April 8, 2018 Scope / Purpose
The primary purposes of a safe work permit are to: Perform a Hazard Assessment Establish a clear line of communications between an Authorized Representative and those who will be performing the work Ensure that all understand the work being performed and the safe work practices to be followed Course Objectives
When course is completed you will be able to: Identify the purposes of a Safe Work Permit Determine a Safe Work Permit is required Perform a Job Site Analysis Control hazards identified by the Job Site Analysis (JSA) Determine who completes the Hazard Assessment Section Identify when to complete Atmospheric Monitoring Section Recognize the Limitations of a Safe Work Permit Determine the Duration of Safe Work Permit Close a Safe Work Permit Determine the frequency required for Atmospheric Monitoring Know when to notify Supervision based upon Atmospheric Monitoring Determine when to issue a Hot Work Permit Set up Fire Watch when appropriate Application
This procedure provides controls and permitting practices for cold or hot work activities A Safe Work Permit should be completed for all work that involves contract personnel unless it is determined to be a Greenfield project. Self-permitting should be completed for higher risk work activity such as:
Atmospheric depressurization
Opening process/piping/exposed energized electrical equipment
Or commissioning new or existing equipment Definitions
Authorized Representative A Company employee/Contract representative properly trained and authorized by the facility/work location Supervision to issue Safe Work Permits Hazard Assessment Job site analysis which identifies hazard(s) in the work space and adjacent areas Hot Work Work involving electric or gas welding, cutting, brazing, grinding or similar flame or spark producing operations Lower Explosive Limit (LEL) The lowest concentration in air that flammable vapors could ignite Responsibility
Proper use and administration of the safe work permit system and the safety of the job rests jointly with the Operations personnel of the areas involved and the maintenance/contract personnel performing the work Both groups – those specifying the work and those performing the work – are required to follow all safety practices required, as well as those indicated and/or checked on the safe work permit Any special and/or additional instructions listed on the permit, job plan and/or procedure must be satisfied before the work commences The Authorized and Contract/Maintenance Representative(s) involved in the work to sign the safe work permit Supervision will ensure the Authorized Representative who completes the safe work permit receives proper training and that the training is documented Maintenance/Contract personnel will be informed of all identified health or physical hazards associated with the work requested and the specific safety procedures or equipment required to protect against exposure Identifying Hazards It takes a hazard and someone exposed to the hazard to produce an accident
Hazard + Exposure Accident7 Identify and Analyze Hazards
Inspections
Determine applicable safety procedure and programs
Review rules and use those you feel apply to your workplace
Develop applicable checklist questions that are not addressed in the rules Observations
Informal and formal, are quite important in daily workplace safety
Employees and managers can spot hazardous conditions and unsafe or inappropriate behaviors while they conduct their other tasks Controlling Hazards
Engineering Controls
Attempt to control hazards through facility design
Most effective form of hazard control Management Controls
Utilize policies and procedures to limit exposure to hazards Personal Protective Equipment
Is utilized when hazards cannot be eliminated or controlled through Engineering and/or Management Controls Job Site Analysis
The Process Break a job or task into specific steps Analyze each step for specific hazardous conditions and unsafe practices Develop preventive measures in each step to eliminate or reduce the hazards
Engineering Controls
Management Controls
Personal Protective Equipment(PPE) Safe Work Permit Flow Diagram
11 Issuing Safe Work Permit
Before any Permit is issued: It will be the responsibility of the Authorized Representative and the maintenance/contract employee requesting the Safe Work Permit to visit the work site together to:
Inspect the work area and identify the specific equipment/system that will be involved in the work
Verify that the equipment/system has been properly prepared for service and/or repairs
Ensure all identified hazards involved with the work have been addressed Safe Work Permit Procedure
Filling Out Safe Work Permit Form Authorized Representative will complete Date, Location/Unit, Equipment/Line ID, Time Issued, Date/Time Expires and Detailed description of work to be performed Emergency Contact Authorized Representative will complete the “Emergency Contact” section of the Safe Work Permit (phone number required) Additional (optional) emergency contact information, assembly and smoking areas can be listed on the back of the field copy Hazard Assessment Section Authorized Representative will perform a hazard assessment by reviewing and checking appropriate boxes in the following sections: Materials/Chemicals/Toxins Forms of Hazardous Energy Physical Hazards Other Permit Requirements Procedure
Filling Out Safe Work Permit Form …continued PPE and Safety Precautions - Based on the hazard(s) identified, the Authorized Representative will identify and check appropriate boxes in the following sections:
Required PPE
Safety Precautions Confined Space – Authorized Representative will complete all check boxes or check NA Trench / Excavation - Authorized Representative will complete all check boxes or check NA Safe Work Permit JSA/Tailgate Meeting
16 Procedure
Filling Out Safe Work Permit Form …continued Atmospheric Monitoring Section – Authorized Representative will Complete the atmospheric monitoring if:
Non-intrinsically safe equipment is used in a classified area (Refer to Safety policy 3.11) or
There is the potential of toxins or hydrocarbons in the permitted area or
Opening piping, vessels or equipment in hydrocarbon service or
Hot work is performed or
Work involves Confined Space Entry Procedure
Filling Out Safe Work Permit Form …continued If work does not meet the conditions, the Authorized Representative will check the NA Box in Atmospheric Monitoring section Hot Work Section - The Authorized Representative will complete the Hot Work Section if the nature of activity is considered hot work by checking appropriate boxes If the nature of work is not considered hot work or is in a non- classified location free of combustible and flammable materials, the Authorized representative will check the NA Box in the Hot Work section Approval Section - Authorized Representative will verify Safe Work Permit is completely filled out and then print and sign name
Contractor / Maintenance Representative will print and sign name
Spaces are provided for additional authorization signatures (i.e., Supervision, Inspection & Safety, etc.) if required by other safety policies or procedures. Issuing Safe Work Permit
The Safe Work Permit is issued by Authorized Representative after ensuring that: All Safety Precautions prescribed on the Safe Work Permit have been satisfied All approval signatures have been obtained Any additional permit(s) or checklists have been completed Completes a Tailgate Safety Meeting with all authorized employee(s) working under the Safe Work Permit. Maintenance/contract employees will complete “accountability log” on back of the soft copy of the Safe Work Permit Safe Work Permit Atmospheric Monitoring Safe Work Permit
Atmospheric Testing The Authorized Representative will determine atmospheric monitoring required (Only one monitoring method applicable per job) Initial Only: After initial monitoring, no additional atmospheric monitoring will be required based on scope of work and hazard assessment Document monitoring results on Atmospheric Monitoring section Periodic: Initial reading and frequency to be documented on the front of permit Subsequent atmospheric monitoring results will be documented on back of field copy Continuous (required for all Hot Work or Confined Space Entry): Monitor running continuously at the work site Monitoring equipment is positioned so personnel at the work site can recognize, communicate and react to the alarm Initial reading and frequency to be documented on the front of permit On a predetermined frequency (not to exceed 2 hours), document subsequent atmospheric monitoring results on back of field copy Safe Work Permit
Atmospheric Testing…continued The Authorized Representative will determine atmospheric monitoring required (Only one monitoring method applicable per job) Will ensure any direct-read monitor used on the work site has been properly calibrated (monthly), function/bump tested (prior to each days use) and documented on the permit Will consult Supervision before proceeding if: Oxygen reading is outside of 19.5% - 23.5% Toxics are > PEL LEL > 0% If atmospheric monitoring has not been performed per the permit’s specified frequency, work must stop until
monitoring has been done and documented22 on the permit. Safe Work Permit Hot Work Permit The Authorized Representative will issue a Safe Work Permit after completing and/or verifying that the following precautionary measures and safeguards have been completed for hot work: If practical, hot work should be relocated to safe work area If the hot work can’t be relocated all moveable combustible material must be moved outside a 35 ft. radius from the hot work area If combustible material can’t be moved it should be covered with fire-proof canvas and/or wetted The use of fire-proof canvas as a protective curtain to contain metal slag and sparks must be provided if necessary to protect personnel and/or reduce the risk of fire Barricades must be provided below any elevated burning or welding activities Valves, piping, flanges and equipment within a 35 ft radius of the job site will be tested with a combustible gas monitor to assure a safe atmosphere around any welding or spark producing operations Safe Work Permit Hot Work Permit Safe Work Permit
Hot Work Permit…continued Drains, ditches, trenches, sumps and other low-lying areas within a 35 ft radius of the job site will be tested with a combustible gas monitor to determine the potential presence of flammable vapors or liquids Fire Watch - A dedicated fire watch will be required whenever grinding, welding, or cutting is performed.
Fire watch will have fire extinguishing equipment readily available and be trained in its use
They will be familiar with procedures for sounding an alarm and/or contacting local emergency services in the event of a fire
They will watch for fires in all exposed areas, try to extinguish them only when obviously within the capacity of the equipment available, or otherwise sound the alarm and/or contact local emergency services
A fire watch will be maintained for at least a 30 minutes after completion of welding or cutting operations to detect and extinguish possible smoldering fires Issuing Safe Work Permit
Limitations The Authorized Representative is responsible to be aware of any changes in the operating area that may affect the validity of the permit as originally issued If permit job site conditions change, the Authorized Representative will inform/instruct all involved personnel of these changes and document on the field copy If work is stopped for any unsafe condition, the permit will be “cancelled” and a new permit must be issued The maintenance/contract employees who perform work authorized by the permit must stop work when permit expires Issuing Safe Work Permit
Posting Each permit will be made in duplicate (or copied)
The field copy will be given to the employee who requested the permit or will be doing the work
The original will remain in control of the Authorized Representative The field copy will be displayed in close proximity to the work being performed Issuing Safe Work Permit
Duration A permit is only valid for the period specified The Authorized Representative will request an estimated time frame that the work activities will take for maintenance or contractors to complete the job Permits may be written to extend from one shift to another provided the oncoming shift is completely advised of the work being done It will be the responsibility of the oncoming Authorized Representative to check the job(s) underway, perform atmospheric monitoring (as needed), update date/time and sign (both copies of) the existing permit Document atmospheric monitoring on back of the field copy
A new permit may be issued instead of updating existing permit Maintenance/contract representative of the oncoming shift will assume full responsibility for each permit presently in effect by signing (both copies) on the Approval section No permit issued within a 24-hour period can be extended beyond the next normal workday All existing permits must be re-issued at the beginning of each workday.
Normal workday is the normal work schedule (06:00, 07:00, etc.) Issuing Safe Work Permit
Closing The employee(s) who perform work authorized by the permit must: Notify Authorized Representative when all permitted work is completed Document the time completed on the field copy Return the field copy of the permit to the Authorized Representative. The Authorized Representative will: Verify that the work has been completed Match-up the completed permit copies File copies at the designated location (where applicable) Course Objectives
What is the purposes of a Safe Work Permit? When is a Safe Work Permit required? What is required for a Job Site Analysis? How do we control hazards identified by the Job Site Analysis (JSA)? Who completes the Hazard Assessment Section? When do we complete the Atmospheric Monitoring Section? What are the Limitations of a Safe Work Permit? What is the Duration of Safe Work Permit? How do you close a Safe Work Permit? What is the frequency required for Atmospheric Monitoring? When do you notify Supervision based upon Atmospheric Monitoring? When do you issue a Hot Work Permit? When is it appropriate to Set up a Fire Watch?
30 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM LOCKOUT/TAGOUT (LOTO) PROGRAM
1) PURPOSE AND SCOPE
This program establishes the safety requirements for the protection of persons servicing and performing maintenance of machines and equipment from injury due to the unexpected energization or startup of machines or equipment, or release of stored energy.
This program applies to the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or the release of stored energy could cause injury to employees. This program does not apply to: (i) oil and gas well drilling and wellhead servicing and Hot Tap operations; (ii) handheld power tools, where a cord can be unplugged to cut power to the equipment when the plug is within control of the operator; (iii) sight glass removal/installation, choke changes, removing/replacement of instruments, pigging operations. Always assume that Lockout/Tagout (LOTO) procedures apply and then check for exceptions.
Reference: OSHA Standard 29 CFR 1910.147
2) POLICY
a) General:
i) Unless otherwise excluded in this program, all machines and equipment shall be Locked Out/Tagged Out to protect against injury due to accidental or inadvertent operation. Employees shall follow the LOTO procedures of this program when performing LOTO. The common types of hazardous energy that employees may be exposed to are: electrical, mechanical, pneumatic, hydraulic, pressure and kinetic. More than one Energy Source may be utilized on some equipment. Employees shall identify each Energy Source and LOTO accordingly.
ii) All equipment shall have equipment specific LOTO procedures.
b) Authorization:
i) LOTO shall be performed only by the Authorized Employees who are performing the servicing or maintenance. Authorized Employees include operators, maintenance personnel, mechanic supervisors, I & E technicians, and electricians
ii) Removal of LOTO Devices shall only be removed by the Authorized Employee who originally placed them on the equipment.
1 of 13 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM LOCKOUT/TAGOUT (LOTO) PROGRAM
iii) Employees shall not attempt to operate or startup equipment that is Locked or Tagged Out (including switches, valve or another Energy-Isolating Device where it is Locked or Tagged Out).
c) Equipment/Materials:
i) Locks, tags, chains, wedges, key blocks, adapter pins, self-locking fasteners or other hardware shall be provided by the Company for isolating, securing or blocking of machines or equipment from Energy Sources.
ii) Approved LOTO Devices shall be the only devices used for controlling energy. These devices shall not be used for other purposes and shall meet the requirements of this section.
iii) Lockout and Tagout Devices shall indicate the identity of the Authorized Employee applying the device.
iv) Selection:
(1) Lockout and Tagout Devices shall be standardized within the facility in at least one of the following criteria: Color, shape or size. Additionally, in the case of Tagout Devices, print and format shall be standardized.
(2) Lockout Devices:
(a) Lockout Devices shall be a padlock, opened by a key. Combination locks are prohibited.
(b) Lockout Devices shall be substantial enough to prevent removal without the use of excessive force or unusual techniques, such as with the use of bolt cutters or other metal cutting tools.
(3) Tagout Devices:
(a) Tagout Devices, including means of attachment, shall be substantial enough to prevent inadvertent or accidental removal.
(b) Tagout Device attachment shall be of a non-reusable type, attachable by hand, self-locking, and non-releasable with a minimum unlocking strength of no less than 50 pounds and having the general design and basic characteristics of being at least equivalent to a one-piece, all- environment tolerant securing device (i.e., nylon cable tie).
(c) Tagout Devices shall warn against hazardous conditions if the machine or equipment is energized and shall include a legend such as the following: “Do Not Start”, “Do Not Open”, “Do Not Close”, “Do Not Energize” or “Do Not Operate”.
2 of 13 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM LOCKOUT/TAGOUT (LOTO) PROGRAM
v) Condition:
(a) LOTO Devices shall be capable of withstanding the environment to which they are exposed for the maximum period of time that exposure is expected.
(b) Message on tags must remain legible and the tags shall be constructed so that exposure to wet and damp or corrosive environments will not cause the tag to deteriorate or corrode. The print and format of tags shall be standardized.
d) Group LOTO:
i) When servicing and/or maintenance is performed by a crew, craft, department or other group, the following group LOTO procedure shall be utilized to afford the employees a level of protection equivalent to that provided by the implementation of a personal LOTO device.
ii) The Company shall designate one of the Authorized Employees in the group as the Primary Authorized Employee. The Primary Authorized Employee shall be primarily responsible for a set number of employees working under the protection of a group LOTO Device. The Primary Authorized Employee must implement and coordinate the group LOTO of hazardous Energy Sources and verify that the steps taken in accordance with the specific written energy control procedure have effectively isolated the machine or equipment from the hazardous Energy Sources. This must be accomplished before Authorized Employees participating in the group LOTO affix their personal LOTO Device to the group LOTO Device and before performing servicing/maintenance activities.
iii) In addition to the verification performed by the Primary Authorized Employee, each Authorized Employee participating in the group LOTO must be informed of their right to verify the effectiveness of the LOTO measures. Each Authorized Employee must be allowed to personally verify that hazardous Energy Sources have been effectively isolated, if they so choose. An Authorized Employee, who opts to verify the effectiveness of the isolation measures, must perform this verification after affixing his or her personal LOTO Device to the group LOTO Device and before performing service or maintenance activities.
iv) Each Authorized Employee shall affix a personal LOTO Device to the group LOTO Device before he or she begins work and shall remove those devices when he or she finishes working on the machine or equipment being serviced or maintained.
3 of 13 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM LOCKOUT/TAGOUT (LOTO) PROGRAM
e) Shift or Personnel Changes:
i) When performing service or maintenance of machinery or equipment that will require shift or personnel changes during this work, continuity of LOTO protection shall be maintained to minimize exposure to hazards from the unexpected energization or start-up of the machine or equipment or the release of stored energy.
ii) Whenever work is being performed under group LOTO, a Primary Authorized Employee must be present at all times. When changing shifts, the Company shall, through an orderly transfer, designate a new Primary Authorized Employee. This new Primary Authorized Employee must attach their personal LOTO Device to the group LOTO Device before the previous Primary Authorized Employee removes their personal LOTO Device. The Primary Authorized Employee will assume the responsibilities previously described in the group LOTO procedures.
iii) Whenever work is performed over a period of time and is not continuous, the Authorized Employee or Primary Authorized Employee (in group LOTO operations) shall walk through the affected work area(s) to verify effective isolation prior to continuing operations. The Authorized Employee or Primary Authorized Employee shall not rely on a job briefing or a LOTO Device. Rather, each applicable Energy-Isolation Device must be verified to assure effective energy isolation.
f) Contractors:
i) Whenever a Contractor is to be engaged in activities covered by the scope and application of this program, the Company and contractor shall inform each other of their respective LOTO procedures.
ii) The site supervisor shall confirm that Affected Employees understand and comply with the contractor’s LOTO procedures.
g) Documentation and Recordkeeping:
i) Employees affected by this program shall have access to the LOTO procedures.
ii) A current list of Authorized Employees shall be maintained.
iii) The inspection certification shall:
(1) identify the machine or equipment on which the energy control procedure was being utilized;
(2) include the date the inspection was completed;
4 of 13 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM LOCKOUT/TAGOUT (LOTO) PROGRAM
(3) include the name(s) of employee(s) included in the inspection; and
(4) include the name(s) of the person(s) performing the inspection.
iv) Training certifications:
(1) The Company shall certify that employee training has been accomplished.
(2) The certification shall contain each employee’s name and dates of training.
(3) Documentation of training will be maintained by the Company.
h) Training and Communication:
i) Initial Training: Training shall be provided to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of energy controls are acquired by employees.
Training shall include the following:
(1) Each Authorized Employee shall receive training in the recognition of applicable hazardous Energy Sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.
(2) Each Affected Employee shall be instructed in the purpose and use of the Lockout/Tagout (LOTO) Program.
(3) All other employees whose work operations are or may be in an area where energy control procedures may be utilized, shall be instructed about the procedure, and about the prohibition relating to attempts to restart or reenergize machines or equipment which are Locked or Tagged Out.
(4) When Tagout systems are used, employees shall also be trained in the following limitations of tags:
(a) Tags are essentially warning devices affixed to Energy-Isolating Devices and do not provide the physical restraint on those devices that is provided by a lock.
(b) When a tag is attached to an energy isolating means, it is not to be removed without authorization of the authorized person responsible for it, and it is never to be bypassed, ignored, or otherwise defeated.
5 of 13 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM LOCKOUT/TAGOUT (LOTO) PROGRAM
(c) Tags must be legible and understandable by all Authorized Employees, Affected Employees, and all other employees whose work operations are or may be in the area, in order to be effective.
(d) Tags and their means of attachment must be made of materials which will withstand the environmental conditions encountered in the workplace.
(e) Tags may evoke a false sense of security, and their meaning needs to be understood as part of the overall energy control program.
(f) Tags must be securely attached to Energy-Isolating Devices so that they cannot be inadvertently or accidentally detached during use.
ii) Retraining: Retraining shall be provided for all Authorized and Affected Employees whenever there is a change in their job assignments, a change in machines, equipment or processes that presents a new hazard, or when there is a change in the energy control procedure.
(1) Additional retraining shall also be conducted whenever a periodic inspection reveals, or whenever the Company has reason to believe, that there are deviations from or inadequacies in the employee’s knowledge or use of the energy control procedures.
(2) The training shall reestablish employee proficiency and introduce new or revised control methods and procedures, as necessary.
iii) The Company shall verify that each Affected Employee has received LOTO training and understands the required training through a written certification. See “Documentation and Recordkeeping” for information regarding training certification.
i) Inspections:
i) Periodic inspections of this program shall be conducted annually, at a minimum.
ii) The inspection shall not be performed by the Authorized Employee using the energy control procedure being inspected.
iii) Each inspection shall include:
(1) a separate review of each energy control procedure;
(2) where Lockout is used for energy control, a review, between the inspector and each Authorized Employee, of that employee’s responsibilities under the energy control procedure being inspected; and
6 of 13 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM LOCKOUT/TAGOUT (LOTO) PROGRAM
(3) where Tagout is used for energy control, a review, between the inspector and each Authorized and Affected Employee, of that employee’s responsibilities under the energy control procedures being inspected.
iv) Person participating in the review shall:
(1) observe a representative sample of Authorized Employees while they are implementing the procedure; and
(2) talk with all other Authorized Employees for comments, even though they may not be implementing the energy control procedure.
v) The Company shall certify that periodic LOTO inspections have been performed. See “Documentation and Recordkeeping” for information regarding inspection certification.
3) PROCEDURES
a) General Locking Out and/or Tagging Out of Equipment: Before maintenance or servicing of machines or equipment the following procedures shall be completed by the Authorized Employee:
i) Notify employees: Affected Employees shall be notified by the Authorized Employee before the application of LOTO devices.
ii) Prepare for shutdown: Perform a survey and identify all isolating devices to determine which switches, valves, or Energy-Isolating Devices apply to the equipment to be Locked or Tagged Out. More than one Energy Source may be involved.
iii) Shutdown machine/equipment: If the machine or equipment is operating, shut it down by using the procedures established for the machine or equipment. An orderly shutdown shall be utilized to avoid any additional or increased hazards to employees as a result of the equipment shutdown.
iv) Isolate machine/equipment : All Energy-Isolating Devices that are needed to control the energy to the machine or equipment shall be physically located and operated in such a manner as to isolate the machine or equipment from the Energy Source(s).
v) Apply LOTO Device: Affix LOTO devices to each Energy-Isolating Device.
(1) Lockout Devices where used shall be affixed in a manner that will hold the Energy-Isolating Devices in a “safe” or “off” position.
7 of 13 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM LOCKOUT/TAGOUT (LOTO) PROGRAM
(2) Tagout Devices shall be affixed in such a manner that clearly indicates that the operation or movement of an Energy-Isolating Device that has been placed in the “safe” or “off” position is prohibited.
(a) Where Tagout Devices are used with Energy-Isolating Devices, the tag attachment shall be fastened at the same point at which the lock would have been attached.
(b) Where a tag cannot be affixed directly to the Energy-Isolating Device, the tag shall be located as close as safely possible to the device, in a position that will be immediately obvious to anyone attempting to operate the device.
vi) Release of stored energy: Following the application of Lockout and/or Tagout Devices to Energy-Isolating Devices, all potentially hazardous stored or residual energy shall be relieved, disconnected, restrained and otherwise rendered safe. If there is a possibility of reaccumulation of stored energy to a hazardous level, verification of isolation shall be continued until servicing or maintenance is completed or until the possibility of such accumulation no longer exists.
vii) Verification of isolation: Prior to starting work on machines or equipment that have been Locked or Tagged Out, the Authorized Employee shall verify that isolation and de-energization of the machine or equipment have been accomplished. Verification means, “trying to start, turn on or activate” the machine.
b) General Release of Locked Out and/or Tagged Out Equipment
Before releasing equipment that is Locked or Tagged Out, the following procedures shall be completed by the Authorized Employee:
i) Ready equipment: Inspect work area to ensure nonessential items have been removed and to ensure that the machine or equipment components are operationally intact. Any guards on equipment shall be replaced and fully functional.
ii) Clear personnel: Verify that all persons have been safely removed and at a safe distance from machine or equipment.
iii) Remove LOTO Device: Remove LOTO Device from each Energy-Isolating Device.
iv) Notify employees: Notify Affected Employees after LOTO Devices have been removed before machine or equipment is started.
c) Electrical (motor controllers, capacitors, circuit breakers, etc.):
8 of 13 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM LOCKOUT/TAGOUT (LOTO) PROGRAM
i) Identify the system to be isolated.
ii) Shut down the equipment by disengaging switch.
iii) Open the master disconnect.
iv) Verify that the power sources are Locked and Tagged Out. If the circuit requires disconnection or removal of an electrical component to ensure isolation, a Qualified Person must perform the work. A Qualified Person is an employee or contractor’s employee who has received training in avoiding the electrical hazards of working on or near exposed energized parts.
v) Discharge stored electrical energy.
vi) When working on or near exposed de-energized electrical equipment, a Qualified Person will use test equipment to verify that all circuits are dead.
d) Pneumatic (starting air, control valves, instrument air):
i) Identify the system to be isolated.
ii) Isolate the system.
iii) Conduct a controlled release of all stored pressure.
e) Hydraulic (valve actuators, presses):
i) Identify the system to be isolated.
ii) Isolate the system.
iii) Conduct a controlled release of all stored pressure.
f) Mechanical (stored Energy Sources, counterweights, tension springs, etc.):
i) Identify the system to be isolated.
ii) Isolate the system.
iii) Block/secure equipment to prevent release of stored energy.
g) Production Equipment (piping systems, vessel, production process equipment, storage tanks, etc.):
i) Identify the system to be isolated.
ii) Isolate all inlet and outlet piping by disconnecting pipes, inserting blinds, or use of double block and bleed.
9 of 13 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM LOCKOUT/TAGOUT (LOTO) PROGRAM
iii) Conduct a controlled release of all stored pressure.
iv) Use Lockout valves, chains or Lockout Devices with padlocks to lock out the Energy Source.
h) When the Authorized Employee who applied the LOTO Device is not available to remove it, the following procedure shall be followed:
i) Notify Supervisor and inform him or her of situation.
ii) Verify that the Authorized Employee who applied the LOTO Device is not at the facility.
iii) Make all reasonable efforts to contact Authorized Employee and inform him or her that his or her LOTO Device has been removed.
iv) Ensure that the Authorized Employee has this knowledge before he or she resumes work.
i) Test or Position Machines and Equipment:
In situations where LOTO Devices must be temporarily removed from the Energy-Isolating Device and the machine or equipment energized to test or position the machine or equipment, the following procedures shall be completed by the Authorized Employee:
i) Follow general procedures under “General Release of Locked Out and/or Tagged Out Equipment.”
ii) Energize and proceed with testing or positioning;
iii) De-energize all systems and re-apply energy control measures in accordance with “General Locking Out and/or Tagging Out of Equipment.”
iv) Continue maintenance or servicing.
4) RESPONSIBILITY
a) Management shall:
i) provide protective materials and hardware; and
ii) promote and enforce program compliance.
b) Supervisors shall:
10 of 13 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM LOCKOUT/TAGOUT (LOTO) PROGRAM
i) verify employees comply with the specific requirements of the program; and
ii) provide employees with the proper LOTO Devices.
c) Authorized Employees shall:
i) comply with all LOTO policy and procedures.
ii) apply LOTO controls in accordance with policy and procedure.
d) Employees shall:
i) not attempt to start up equipment and machinery that is Locked and/or Tagged Out.
ii) not remove any locks or tags on equipment and machinery.
5) DEFINITIONS
a) Affected Employee - An employee whose job requires him or her to operate or use a machine or equipment on which servicing, or maintenance is being performed under Lockout or Tagout, or whose job requires him or her to work in an area in which such servicing or maintenance is being performed.
b) Authorized Employee – An employee who either (i) Locks or Tags Out machinery in order to perform service or maintenance, or (ii) implements a Lockout and/or Tagout system procedure on machines or equipment such as performing Energy Source isolation, implementing LOTO, releasing stored energy, verifying energy isolation, releasing LOTO, or testing or positioning machinery or equipment. An Authorized Employee and an Affected Employee may be the same person when the Affected Employee’s duties also include performing maintenance or service on a machine or equipment, which must be Locked or Tagged Out.
c) Capable of Being Locked Out - An Energy-Isolating Device will be considered to be capable of being Locked Out if either 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-Isolating Devices will also be considered to be 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.
d) Energized - Connected to an Energy Source or containing residual or stored energy.
e) Energy-Isolating Device - A mechanical device that physically prevents the transmission or release of energy, including, but not limited to, the following: a
11 of 13 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM LOCKOUT/TAGOUT (LOTO) PROGRAM
manually operated electrical circuit breaker; a disconnect switch; a manually operated switch by which the 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, and other control circuit-type devices.
f) Energy Source - Any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy.
g) Exclusions – Those conditions, situations and work that may not apply:
i) work on cord and plug-connected electric equipment for which exposure to the hazards of unexpected energization or start up of the equipment is controlled by the unplugging of the equipment from its single Energy Source and by the plug being under the exclusive control of the one and only employee performing the servicing;
ii) minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, if they are routine, repetitive, and integral to the use of the equipment, provided that the work is performed using alternative measures which provide effective protection, and;
iii) Hot Tap operations involving transmission and distribution systems for substances such as gas, steam, water, or petroleum products when they are performed on pressurized pipelines, provided that the Company demonstrates that: (1) continuity of service is essential; (2) shutdown of system is impractical; and (3) documented procedures are followed, and special equipment is used which will provide proven, effective protection for employees.
h) Hot Tap - A procedure used in the repair, maintenance, and services activities, which involves welding on a piece of equipment (pipelines, vessels, or tanks) under pressure, in order to install connections or appurtenances. It is commonly used to replace or add sections of pipeline without the interruption of service for air, gas, water, steam, and petrochemical distribution systems.
i) 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.
j) Lockout Device - A device that utilizes a positive means such as a lock, either key or combination type, to hold an Energy-Isolating Device in a safe position and prevent the energizing of a machine or equipment.
k) Normal Production Operations - The utilization of a machine or equipment to perform its intended production function.
12 of 13 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM LOCKOUT/TAGOUT (LOTO) PROGRAM
l) Primary Authorized Employee - The Authorized Employee primarily responsible for a set number of employees working under the protection of a group LOTO Device.
m) 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 or unjamming of machines or equipment and making adjustments or tool changes, where the employee may be exposed to startup of the equipment or release of hazardous energy.
n) Setting Up - Any work performed to prepare a machine or equipment to perform its normal production operation.
o) 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.
p) 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.
13 of 13 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM PERSONAL PROTECTIVE EQUIPMENT (PPE) PROGRAM
1) PURPOSE AND SCOPE
This program establishes the requirements for selecting, using and maintaining Personal Protective Equipment (PPE) to protect employees from the risk of injury from the hazards they may face in the workplace.
Reference: OSHA Standard 29 CFR 1910.132, 133, 135, 136, 137 and 138
2) POLICY
a) General: Engineering controls shall be the primary methods used to eliminate or minimize hazard exposure in the workplace. When such controls are not practical or applicable, PPE shall be used by employees to reduce or eliminate exposure to hazards.
b) Equipment/Materials (PPE):
i) PPE shall be provided to employees, where required at no charge to the employee. There are some exceptions. See PPE matrix for further required versus provided detail.
ii) PPE shall be used within its designed and stated purposes, in accordance with the manufacturer’s and other applicable standards.
iii) PPE shall bear the appropriate markings and labels testifying to its construction in accordance with applicable standards.
iv) PPE shall be of a safe design and construction for the work to be performed and shall conform to existing standards requirements, the American National Standards Institute (ANSI) and the National Institute for Occupational Safety and Health (NIOSH).
v) Select PPE that provides appropriate protection from the specific hazards present in the work to be performed. Consult manufacturer’s guidelines for assistance.
vi) Select PPE that properly fits each affected employee.
vii) Condition:
(1) Protective Equipment, including PPE for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be maintained in a sanitary and reliable condition.
1 of 6 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM PERSONAL PROTECTIVE EQUIPMENT (PPE) PROGRAM
(2) Defective or damaged PPE, or other Protective Equipment, shall not be used and shall be removed from service. Consult manufacturer’s guidelines for assistance.
(3) Contaminated PPE, which cannot be decontaminated, shall be properly disposed of and in a manner that protects employees from exposure to hazards.
viii) Inspections:
(1) PPE shall be inspected in accordance with the manufacturer’s instructions; and
(2) PPE shall be inspected before and after each use.
ix) Employee Owned Equipment:
(1) Where employees provide their own PPE, the Company shall be responsible for verifying that such PPE is adequate, properly maintained, and properly sanitized.
(2) Employee owned equipment shall offer, at least, the equivalent level of protection offered by Company provided PPE.
c) Using (PPE):
i) All PPE shall be donned, used and doffed in accordance with manufacturer’s instructions.
ii) If at any time while using PPE it becomes damaged, otherwise unserviceable or fails to protect user from the hazard(s), the user shall:
(1) stop working immediately;
(2) leave the hazardous area;
(3) replace PPE if PPE is damaged; and
(4) consult with a supervisor if selected PPE is not effective.
d) Hazard Assessment:
i) The Company shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of PPE.
ii) The Company shall verify that the required workplace hazard assessment has been performed, documented, and posted in the workplace.
2 of 6 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM PERSONAL PROTECTIVE EQUIPMENT (PPE) PROGRAM
e) Contractors: All contractors working inside Company facilities are required to follow the requirements of this program.
f) Documentation and Recordkeeping:
i) The Company shall make records available to any employee affected by this program.
ii) The hazard assessment shall contain:
(1) the identity of the workplace evaluated;
(2) the name of the person certifying that the assessment has been performed;
(3) the date(s) of the hazard assessment; and
(4) hazard assessment results.
iii) Training certifications:
(1) The training certification shall contain each employee’s name, the dates of training and the subject of the certification.
(2) Documentation of training will be maintained by the Company.
g) Training and Communication:
i) Initial Training Policy:
(1) All employees who are required to use PPE shall be trained by the Company, at no cost to the employee, before employee is allowed to use PPE. Initial training may be computer based training, hands on training or safety meeting.
(2) Each employee required to use PPE shall be trained to know, at least the following, about each piece of PPE they are required to use:
(a) when PPE is necessary;
(b) what PPE is necessary;
(c) how to properly don, doff, adjust and wear PPE;
(d) the limitations of the PPE; and
(e) the proper care, maintenance, useful life and disposal of the PPE.
3 of 6 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM PERSONAL PROTECTIVE EQUIPMENT (PPE) PROGRAM
(3) Each employee required to use PPE shall demonstrate an understanding of the training specified in this section, before being allowed to perform work requiring the use of PPE.
ii) Retraining Policy:
(1) When the Company has reason to believe that any affected employee who has already been trained does not have the understanding and skill required, the Company shall retrain each such employee.
(2) Circumstances where retraining is required include, but are not limited to, situations where:
(a) changes in the workplace render previous training obsolete;
(b) changes in the types of PPE to be used render previous training obsolete; or
(c) inadequacies in an affected employee's knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill.
iii) The Company shall verify that each affected employee has received PPE training and understands the required training through a written certification. See “Documentation and Recordkeeping.”
3) PROCEDURES
a) Conducting a Hazard Assessment :
In order to adequately assess the need for PPE:
i) Conduct a walk through survey of the areas in question. Consideration should be given to the basic hazard categories: impact, penetration, compression (roll-over), chemical, heat, harmful dust, and light (optical) radiation.
During the walk-through survey, observe the following:
(1) sources of motion; e.g. machinery or processes where any movement of tools, machine elements or particles could exist, or movement of personnel that could result in collision with stationary objects;
(2) sources of high temperatures that could result in burns, eye injury or ignition of Protective Equipment, etc.;
(3) types of chemical exposures;
4 of 6 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM PERSONAL PROTECTIVE EQUIPMENT (PPE) PROGRAM
(4) sources of harmful dusts;
(5) sources of light radiation; e.g. welding, brazing, cutting, furnaces, heat treating, high intensity lights, etc;
(6) sources of falling objects, or potential for dropping objects;
(7) sources of sharp objects which might pierce the feet or cut the hands;
(8) sources of rolling or pinching objects which could crush the feet;
(9) layout of workplace and location of co-workers; and
(10) any electrical hazards.
ii) In addition, injury/accident data should be reviewed to help identify problem areas.
iii) Having gathered and organized data on a workplace, an analysis of the potential for injuries should be made. Each of the basic hazards listed above should be reviewed and a determination made as to the type, level of risk, and seriousness of potential injury from each of the hazards found in the area. The possibility of exposure to several hazards simultaneously should be considered.
4) RESPONSIBILITY
a) Management shall:
i) provide appropriate PPE and other Protective Equipment for use by employees; and
ii) promote and enforce program compliance.
b) Supervisors shall:
i) verify employees wear appropriate, serviceable PPE for protection from hazards;
ii) periodically inspect PPE used by employees to verify it is being used and maintained in accordance with this program; and
iii) perform hazard assessment certifications as required before performing work.
c) Employees shall:
5 of 6 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM PERSONAL PROTECTIVE EQUIPMENT (PPE) PROGRAM
i) comply with the safety requirements of the program; and
ii) select, use, maintain and inspect PPE in accordance with this program.
5) DEFINITIONS
a) Doff – Another word to define taking off PPE.
b) Don – Another word to define putting on PPE.
c) Personal Protective Equipment (PPE) – Refers to protective materials and/or equipment designed to protect the body and its parts from impact, compression, sharp objects, absorption or splashing, harmful light/rays or otherwise contact with harmful substances.
d) Protective Equipment – Other barriers or insulating devices used to shield employees from hazards.
6 of 6 14 Respiratory Protection Program
Approved: Ronald T. Evans, CEO Document number: 02-2019 Revision No: 1 Revised: 08/08/2019
CONTENTS
Subsection Topic 1.0 Purpose / Scope Page 2 2.0 Applicability Page 2 3.0 General Respiratory Protection Policy Page 2 4.0 Responsibilities Page 3 5.0 Hazard Control Page 4 6.0 Contractors Page 4 7.0 Selection of Respirators Page 5 8.0 Medical Evaluation Page 6 9.0 Fit Testing Page 7 10.0 Use of Respirators Page 7 11.0 Maintenance and Care of Respirators Page 10 12.0 Breathing Air Quality and Use Page 11 13.0 Identification of Filters, Cartridges and Canisters Page 12 14.0 Respiratory Protection Program Evaluation Page 12 15.0 Training Page 13 16.0 Relationship to Contractual Agreements Page 14 17.0 Relevant Company Programs Page 14 18.0 Document Management Page 15 19.0 Regulatory References Page 15 Appendix A Hazard / Respirator Selection Guide Page 16 Appendix B Assigned Protection Factors Page 17
1 of 17
Respiratory Protection Program Revised: 08/08/2019
1. PURPOSE / SCOPE
1.1 The Respiratory Protection Program establishes the expectations, conditions and procedures applicable to using respiratory protection at all locations of Geo Fossil Fuels, Tabula Rasa Energy and Perdure Petroleum (Company). The Respiratory Protection Program has been developed to ensure that respirators are properly selected, fitted, used and maintained to protect the health of employees. The Respiratory Protection Program contains the following elements (per 29 CFR §1910. 134). : A. Procedures for selecting respirators for use in the workplace; B. Medical evaluation for employees required to use respirators; C. Fit testing procedures; D. Procedures for proper use of respirators; E. Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and maintaining respirators; F. Procedures to ensure adequate breathing air quality; G. Training of employees in the respiratory hazards to which they may be exposed, and proper use of respirators; and H. Procedures for regularly evaluating the effectiveness of the program;
2. APPLICABILITY
2.1 This Program applies to work performed by Company employees when respirators are required to perform assigned duties. Respiratory protection is required when exposure to respiratory hazards cannot be controlled be either engineering or administrative controls.
2.2 Potential hazards identified outside the guidelines of the Respiratory Protection Program shall be referred to the local HSE representative or the Director - HSE. The Area/Location Supervisor/Person in Charge (PIC) is responsible for securing the work area until the potential hazard can either be eliminated or safely managed.
3. GENERAL RESPIRATORY PROTECTION POLICY
3.1 Employees exposed to potential respiratory hazards, including oxygen deficient atmospheres (below 19.5% oxygen) or airborne contaminants (e.g.: solid particles, liquid particles, gases/vapors), shall conduct work in accordance with the Respiratory Protection Program. Activities requiring respiratory protection will be reviewed with the GFF/Perdure/Tabula Rasa Safe Work Permit/JSA (Job Safety Analysis) Form prior to the initiation of work so that appropriate plans be developed and reviewed and operating and safety equipment can be secured, inspected and approved for work.
2 of 17
Respiratory Protection Program Revised: 08/08/2019
3.2 Employees are not authorized to use a respirator unless: A. The employee has completed the Respirator Medical Evaluation Questionnaire; B. A written opinion authorizing medical clearance for respirator use has been obtained from the approved Physician or other Licensed Health Care Provider (PLHCP). C. The employee has passed the fit test; and D. The employee has been properly trained.
4. RESPONSIBILITIES
4.1 Employee – Employees are responsible for being familiar with the safe work practices identified in the Respiratory Protection Program and applying it to their work site. Employees must be able to recognize the potential health hazards associated with contaminated atmospheres and the need to use respiratory protection.
A. Employees shall be responsible for their personal compliance with the Respiratory Protection Program, following establish procedures, recognizing and respecting the potential health hazards associated with contaminated atmospheres, using the appropriate respiratory protection and assuring that the available respiratory and other safety equipment to be utilized is operable and effective.
B. Employees are responsible for using, inspecting, cleaning and maintaining the respiratory protection equipment in accordance with the instructions and training provided.
C. Employees are responsible for completing the Respiratory Medical Evaluation Questionnaire.
4.2 Area/Location Supervisor/PIC’s responsibilities include:
A. Ensuring that employees identified for respirator usage are medically approved, have passed the fit test and have been properly trained in the use of respiratory protection;
B. Ensuring that the appropriate respiratory protection equipment is available when needed and that the equipment is maintained; and
C. Reporting any implementation problems to their local safety representative, or the Director - HSE.
3 of 17
Respiratory Protection Program Revised: 08/08/2019
4.3 Respiratory Protection Program Administrator – The Director – HSE is designated as the Respiratory Protection Program Administrator (assisted by the local HSE representative(s) for their area of responsibility). The Director - HSE is responsible for overseeing the implementation, administration, evaluation, revising and updating of the respiratory protection program, as necessary.
4.4 Senior VP of Operations and Operations Management – Operations will implement the Respiratory Protection Program, develop site-specific applications, annually review these procedures and monitor its application to assure compliance.
5. HAZARD CONTROL Hazard control is: 1) the use of engineering controls, 2) administrative controls and 3) personal protective equipment (PPE). The priority or preference of use is in exactly this order.
5.1 Engineering controls are those practices that can be implemented to reduce or eliminate the hazard through the physical change in the work environment. Engineering controls include the utilization of equipment which can ventilate the contaminated atmosphere and reduce the contamination below acceptable levels.
5.2 Administrative controls are the use of policies, work practices and employee training to reduce exposure to the hazard. Administrative controls include allowing only trained employees to be use respiratory equipment, and designating roles, responsibilities and authorizations.
5.3 PPE controls are barriers that protect the wearer from the hazard, such as contaminated atmospheres. PPE should be considered a last line of defense against injury and not the means for eliminating the hazard. PPE includes supplied air respirators such as Self-Contained Breathing Apparatus (SCBA) and airline respirators.
6. CONTRACTORS
6.1 Whenever contractors are to be engaged in activities requiring respiratory protection, the Area/Location Supervisor/PIC, in conjunction with the local HSE representative, will assure that the contractor has a respiratory program.
6.2 Contract personnel are required to provide their own monitoring and respiratory protection equipment.
4 of 17
Respiratory Protection Program Revised: 08/08/2019
6.3 Any issues will be discussed and resolved prior to commencement of the work.
7. SELECTION OF RESPIRATORS
7.1 Respirators will be selected on the basis of hazards to which the employee is exposed. Respirators that are approved and certified by the National Institute for Occupational Safety and Health (NIOSH/Mine Safety Health Administration (MSHA), or equivalent international standard, shall be selected and used in compliance with their condition of certification.
7.2 Employees shall only be permitted to use Company provided respirators.
7.3 In order to select the proper respiratory protection, an assessment of the inhalation hazard is required. There are two basic types of respiratory hazards:
A. Oxygen deficient atmospheres; and B. Airborne contaminants.
7.4 Some of the predominant exposure hazards encountered that require the use of respiratory protection equipment are listed in Appendix A. This nonexclusive guide provides a reference that can be used as a starting point when selecting the type of respirator to use for a particular job hazard.
A. The Area/Location Supervisor/PIC and the Director - HSE will document the potential respiratory hazards for the area/location and the appropriate respiratory protection.
7.5 Only full facepiece positive pressure self-contained breathing apparatus (SCBA) or full facepiece positive pressure airline respirators with a full emergency egress bottle shall be used when an employee is exposed to hydrogen sulfide (H2S), oxygen deficient or atmospheres Immediately Dangerous to Life or Health (IDLH). Additional information regarding H2S may be found in the H2S Safety Policy.
7.6 Air purifying respirators (APRs) may be used only with authorization by the Director - HSE. APRs can be used when contaminants are present in concentration which exceed permissible exposure limits/threshold limit values (PEL/TLV) but are less than Immediately Dangerous to Life or Health (IDLH) atmospheres. APRs may not be used for H2S or oxygen deficient atmospheres. APRs must only be used in accordance with manufacturer’s guidelines for the contaminants they are designed to protect against.
5 of 17
Respiratory Protection Program Revised: 08/08/2019
7.7 Disposable respirators (particulate/dust masks) are only intended to be used for nuisance dusts (sweeping dust, mowing grass, sawdust, etc.). They are not suitable for protection from any hazardous substance including paint.
8. MEDICAL EVALUATION
8.1 A Respirator Medical Evaluation Questionnaire shall be completed by each employee who will be expected to use a respirator.
A. This Respirator Medical Evaluation Questionnaire will be completed: 1. During the employment process; 2. Prior to an employee’s new job assignment; or 3. Every 2 years.
B. The Respirator Medical Evaluation Questionnaire can be provided by HSE personnel.
8.2 The Respirator Medical Evaluation Questionnaire shall be reviewed and a written opinion authorizing medical clearance for respirator use obtained from the PLHCP prior to the employee being assigned to use a respirator in the workplace.
8.3 Additional medical evaluations are required when:
A. The employee reports medical signs or symptoms related to the ability to use respirators;
B. A Physician or other Licensed Health Care Provider (PLHCP), supervisor, Director - HSE, or person conducting fit testing recommends reevaluation.
C. Information from the Respiratory Protection Program, including observations made during fit testing and Program evaluation, indicates a need for employee reevaluation;
D. A change in workplace conditions occurs that my result in a substantial increase in the physiological burden placed on an employee.
8.4 Medical Evaluation Questionnaires and all related medical opinions and reports shall be handled confidentially. Medical records will be maintained by the HSE or Human Resources Department.
6 of 17
Respiratory Protection Program Revised: 08/08/2019
9. FIT TESTING
9.1 Employees subject to wearing respiratory protection shall achieve a successful facepiece fit with the type of respirator required to be won on the job.
9.2 Proper fit shall be assured prior to initial use of the respirator, annually and whenever a different respirator facepiece is used or a change in the employee’s physical condition occurs that could affect respirator fit.
9.3 The Director - HSE will be responsible for arranging fit testing. The results of the fit testing shall be documented, and records of the fit testing shall be maintained at the local office.
9.4 Fit testing protocols must comply with the requirements contained in 29 CFR §1910. 134.
10. USE OF RESPIRATORS
10.1 Employees are required to use respirators in accordance with the instruction and training provided. Approved respirator users shall have successfully passed a medical evaluation, fit test and Respiratory Protection Program training program. Those employees approved to use the respirators shall be identified.
10.2 Air Purifying Respirators (APRs)
A. APRs will not be used unless authorized by the Director - HSE.
B. APRs can be used to provide protection at exposure levels up to ten times the eight-hour exposure limit. APRs shall not be used when the contaminant does not have an easily detectable odor or taste (poor warning properties) or where the oxygen content is less than 19.5 percent. Under no circumstances shall an APR be used in a H2S or oxygen deficient atmosphere, or when there is an H2S hazard.
C. Disposable respirators (particular/dust masks) shall only be used for nuisance dust. Disposable respirators shall be disposed of at the end of at the end of the task or workday, whichever comes first.
7 of 17
Respiratory Protection Program Revised: 08/08/2019
10.3 Self-Contained Breathing Apparatus (SCBA) and Airline Respirators
A. Positive pressure SCBA or airline respirators with egress bottles shall be used in oxygen deficient, H2S or Immediately Dangerous to Life or Health (IDLH) atmospheres.
B. SCBA or airline respirators shall be used when entering a suspected or known hazardous area or when conditions are IDLH.
C. Whenever SCBA or airline respirators are used in IDLH environments, a standby person shall be present with suitable respiratory protection and rescue equipment. During open hatch tank gauging when the potential for an IDLH atmosphere exists (e.g.: 100ppm H2S measured at the thief hatch), a standby person shall be present. Emergency situations requiring the use of SCBA or airline respirator may include leaks, blowouts, spills and rescue operations. If IDLH conditions are present, only airline respirators with egress bottles or positive pressure SCBA shall be used.
10.4 Escape Only Respirators and Egress Bottles A. Escape only respirators and egress bottles are designed for escape only and shall not be used when controlling a release, normal work activities or attempting a rescue.
10.5 Facial Hair Policy
A. Employees who may wear, must wear or will wear respirators in the performance of their regular duties, or for emergency response shall have no facial hair between the face to facepiece seal of the respirator mask, and no hair that interferes with valve function.
10.6 Corrective Lenses
A. Prescription eyewear or goggles must be worn in a manner that they do not interfere with the seal of the facepiece of the face. Employees who require prescription eyewear to perform job related tasks and who use respiratory protection equipment will be provided with lens/frames and a mounted spectacle kit that accommodates the use of prescription lenses.
8 of 17
Respiratory Protection Program Revised: 08/08/2019
10.7 Contact Lens
A. Contact lens may be worn by employees with supervisor approval. The supervisor will discuss contact usage with Director - HSE. The contact lens wearer will inform their co-workers of contact lens usage.
B. The contact lens wearer shall be required to practice wearing the respirator while wearing contact lens. The employee must demonstrate that the contract lenses do not interfere with the use of the respirator.
10.8 Physical Limitations
A. If scars, the absence of teeth or dentures, or unusual facial configuration prevent the wearer from achieving a seal between the respirator facepiece and the wearer’s face, the employee shall not be allowed to wear respiratory protection.
10.9 User Seal Check
A. Employees are to perform a user seal check to ensure that an adequate seal is achieved each time the respirator is put on. Either the positive and negative pressure checks, as provided in 29 CFR § 1910.134, or the respirator manufacturer’s recommended user seal check method shall be used. User seal checks are not substitutes for quantitative fit test (QNFT) or qualitative fit test (QLFT). Masks that cannot be user seal checked are not acceptable for use.
10.10 Voluntary or Non-Mandatory Use of Respirators
A. The voluntary or non-mandatory use of respiratory equipment other than a disposable respirator (particulate / dust mask) requires approval from the Director - HSE.
1. Voluntary or non-mandatory use of a respirator is using a respirator when exposure to the amount of a hazardous substance does not exceed permissible exposure limits.
2. Voluntary use of air purifying (cartridge equipped) respirators or supplied air respirators will require full participation in the respiratory protection program, including completing a medical evaluation questionnaire, review of the questionnaire by a physician or other licensed health care professional (PLHCP), fit testing and training.
9 of 17
Respiratory Protection Program Revised: 08/08/2019
11. MAINTENANCE AND CARE OF RESPIRATORS
11.1 All respirators shall be cleaned, stored, inspected and repaired as per manufacturer recommended procedures or as outlined below.
11.2 Cleaning and Disinfecting
A. Routinely used respirators issued for the exclusive use of an employee shall be cleaned and disinfected as often as necessary to be maintained in a sanitary condition.
B. Respirators used by more than one employee for an emergency use must be cleaned and disinfected after each use.
C. Respirators shall be cleaned and disinfected using the procedure recommended by the respirator manufacturer.
11.3 Storage
A. Respirators shall be stored to protect against physical damage, dust, sunlight, extreme temperatures, moisture or damaging chemicals and shall be packed and stored to prevent deformation of the facepiece and exhalation valve.
B. Respirators designated for emergency use should be strategically locked for quick accessibility in clearly marked and highly visible compartments. Emergency use respirators shall be stored fully charged.
C. Routinely used or non-emergency respirators should be stored in carrying cases as provided by the manufacturer.
11.4 Inspection
A. All respirators used in routine situations shall be inspected by the wearer immediately prior to each use and during cleaning. A user seal check shall be performed by the wearer immediately prior to entering hazardous atmosphere.
B. SCBAs and respirators maintained for use in emergency situations shall be inspected monthly. The monthly inspection shall be documented and maintained.
C. The Area/Location Supervisor/PIC is responsible to assure the monthly inspections are completed and documented.
10 of 17
Respiratory Protection Program Revised: 08/08/2019
D. The inspection shall include a check of the tightness of the connections and the condition of the facepiece, headbands, valves, hoses, regulators, and warning devices. Rubber or elastic parts shall be inspected for pliability and signs of deterioration. Air cylinders are required to be inspected for pressure which must be at least 90 percent of the manufacturer’s recommended pressure level.
E. Defective equipment shall be removed from service and tagged with warning label until properly repaired or replaced.
11.5 Repairs
A. Replacement of parts or repairs shall be performed only by qualified and authorized personnel using parts manufactured for that particular respirator. No adjustment or repairs shall be attempted beyond the manufacturer’s recommendations.
B. Valve and regulator repair shall be performed only by the respirator manufacturer or authorized service representative.
C. Suspect or defective cylinders shall be returned to the manufacturer or authorized service representative.
12. BREATHING AIR QUALITY AND USE
12.1 Compressed breathing air shall meet the requirements of Type 1-Grade D breathing air classification in the ANSI/Compressed Gas Association Commodity Specification G-7.1 or equivalent international standard. This means that the oxygen content must be that normally present in atmospheric air of 19.5 to 23.5 percent oxygen, hydrocarbon of 5 milligrams per cubic meter of air or less carbon monoxide of 10 PPM or less, carbon dioxide of 1000 PPM or less and lack of a noticeable odor . 12.2 Cylinders of purchased breathing air must have a certification of analysis from the supplier that the breathing air meets the requirements of Type 2- Grade D air and moisture content. This documentation shall be kept on file at the local office.
12.3 Compressed oxygen shall never be used in an airline respirator or an open circuit SCBA. All breathing air couplings must be incompatible with outlets for other gas systems to prevent inadvertent servicing of airline respirators with non-respirable gases or oxygen.
11 of 17
Respiratory Protection Program Revised: 08/08/2019
12.4 Breathing air cylinders shall be maintained as prescribed in the Shipping Container Specification Regulations of the Department of Transportation (49 CFR part 173 and part 178) or equivalent international standard.
12.5 Breathing air cylinders shall be marked in accordance with the NIOSH respirator certification standard, 42 CFR Part 84 or equivalent international standard.
13. IDENTIFICATION OF FILTERS, CARTRIDGES OR CANISTERS
13.1 Filters, cartridges or canisters will only be used with the authorization of the Director - HSE.
13.2 The proper filters, cartridges, or canisters must be selected and used only in accordance with manufacturer’s guidance for the contaminants they are designed to protect against. The primary means of identifying the proper filter, cartridge or canister shall be from properly worded labels. The secondary method of identifying a filter, cartridge, or canister shall be by color code. The marking or filters, cartridges, or canisters with the appropriate NIOSH approval label, or equivalent international standard, is the responsibility of the respirator manufacturer.
13.3 Before any filter, cartridge, or canister is placed in service, the Area/Location Supervisor/PIC shall assure that the proper NIOSH or equivalent international standard approval label is in place. Filters, cartridges and canisters with NIOSH or the equivalent international approval labels removed, obscured or defaced shall be removed from service and discarded.
13.4 Air purifying respirators must be equipped with end-of-service-life indicators (ESLI) certified by NIOSH for the contaminants they are designed to protect against (or equivalent international standard). If appropriate ESLI are not available, then the Director - HSE shall be consulted to determine the service life or change out schedule.
14. RESPIRATORY PROTECTION PROGRAM EVALUATION
14.1 The Respiratory Protection Program will be evaluated by the Director - HSE as necessary to ensure that the provisions of the program are being effectively implemented. The evaluation of the program may be documented with the Respiratory Protection Program Evaluation Checklist and shall include:
A. Respirator selection; B. Medical evaluation process;
12 of 17
Respiratory Protection Program Revised: 08/08/2019
C. Fit testing procedures; D. Use of respirators; E. Inspection, maintenance, cleaning and storage procedures; F. Air quality assurance; G. Training; and H. Wearer acceptance.
14.2 The Respiratory Protection Program shall regularly consult employees required to wear respirators to assess the person’s view on Respiratory Protection Program effectiveness and to identify and problems. Problems discovered during Respiratory Protection Program Evaluation will be promptly corrected in order to maintain the Program effectiveness.
15. TRAINING
15.1 Frequency
A. Initial Training - Employees shall be initially trained to ensure familiarity with the Respiratory Protection Program. Employees’ understanding will include: the purpose, function and restrictions of the Respiratory Protection Program; ability to identify when respiratory protection is required; ability to select the appropriate respiratory protection; the limitations of respiratory protection; and, knowledge to maintain, care and store the respiratory protection equipment.
B. Retraining – Employee shall receive retraining whenever there is a change in: 1. Their job assignment; 2. Activities that present hazards for which an employee has not been previously trained; 3. The available respiratory equipment; or 4. The Respiratory Protection Program or regulatory requirements.
C. Refresher Training – Employees shall receive annual refresher training in this Program in accordance with their assigned responsibilities.
D. Certification – Company will certify that the training outlined in the Respiratory Protection Program has been accomplished. The certification will contain the employee’s name and signature, the signature of the trainer, the dates of training and documentation of the employees understanding of the material.
13 of 17
Respiratory Protection Program Revised: 08/08/2019
15.2 Learning Objectives – Upon completion of the lesson, participants will be able to:
A. Understand the purpose, function and requirements of the Respiratory Protection Program; B. Define terms such as: Oxygen Deficient Atmospheres, Airborne Contaminants, IDLH, Medical Evaluation, Fit Testing, SCBA, Air Purifying Respirators, Airline Respirators; C. Identify the hazards associated with contaminated atmospheres; D. Know and report the types of medical or physical changes that require the completion of a new Respiratory Medical Evaluation Questionnaire; E. Know when and why the respirator is necessary and how improper fit, usage or maintenance can compromise the protection intend by using the respirator; F. Know where to look for guidance on proper section of respiratory protection; G. Know how to obtain the respiratory protection available at the location; H. Understand the proper use of respiratory protection; I. Understand the limitations and capabilities of respiratory protection; J. Know how to inspect, put on and remove, use and check the seals of the respirator; K. Know how to properly maintain, clean and store respiratory protective equipment; L. Know how to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions; and M. Understand the various roles of all employees in the Respiratory Protection Program.
16. RELATIONSHIP TO CONTRACTUAL AGREEMENTS
Nothing contained in this guidance document shall be construed as altering in any way the rights, duties and/or obligations contained in any way applicable contract or master service agreement (“Contract”) between parties. Where a conflict arises between this guidance and the Contract, the language of the Contract (MSA) shall be controlling.
17. RELEVANT COMPANY POLICIES AND PROGRAMS • Hydrogen Sulfide (H2S) Safety Policy. (Section 18 of the HSE Policy Manual) • Personal Protective Equipment Program. (and Section 7 of the HSE Policy Manual)
14 of 17
Respiratory Protection Program Revised: 08/08/2019
18. DOCUMENT MANAGEMENT
18.1 The retention of written records such as work plans, permits, monitoring records, fit testing results, program evaluations, respirator inspection and maintenance records, list of approved respirator users, breathing air quality analysis and audits shall be retained by the Director – HSE in accordance with the Respiratory Protection Program.
18.2 The Physician or other licensed health care professional’s (PLHCP) written opinion, recommendations and any results of medical examinations or tests performed shall be retained in accordance with the Respiratory Protection Program. All medical records shall be retained by the Director – HSE in accordance with the Respiratory Protection Program. Medical records include the following:
A. Respirator Medical Evaluation Questionnaire; B. PLHCP written recommendation regarding employee’s ability to use the respirator; and C. Additional Medical Evaluations.
18.3 Employee training records, including attendance sheets and exams, shall be retained by the Director - HSE. The original records shall be maintained in the Allen Corporate Office.
19. REGULATORY REFERENCES
OSHA General Industry A. 29 C.F.R. § 1910.132, General Requirements (See PPE for standard) B. 29 C.F.R. § 1910.133, Eye and Face Protection (See PPE for standard) C. 29 C.F.R. § 1910.134, Respiratory Protection
15 of 17
Respiratory Protection Program Revised: 08/08/2019
APPENDIX A
Hazard / Respirator Protection Guide
16 of 18 Respiratory Protection Program Revised: 08/08/2019
APPENDIX B
Assigned Protection Factors
The Company must use the Assigned Protection Factors listed in the table below 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), the Assigned Protection Factor must be appropriate to the mode of operation in which the respirator is being used.
Assigned Protection Factors5 Type of Quarter Half Full Helmet/ Loose-Fitting Respirator1,2 Mask Mask Facepiece Hood Facepiece Air-Purifying Respirator 5 103 50 -- -- Powered Air-Purifying -- 50 1,000 25 Respirators (PAPR) 25/1,0004 Supplied-Air Respirator
(SAR) or Airline Respirator Demand mode -- 10 50 -- -- Continuous flow mode -- 50 1,000 25/1,0004 25 Pressure-demand or other positive-pressure -- 50 1,000 -- -- mode Self-Contained Breathing
Apparatus (SCBA) Demand mode -- 10 50 50 -- Pressure-demand or other positive-pressure -- -- 10,000 10,000 -- mode (e.g., open/closed circuit) 1The Company 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. 2The Assigned Protection Factors in Table 1 are only effective when the Company implements a continuing, effective respirator program as required by (29 CFR 1910.134, including training, fit testing, maintenance, and use requirements. 3This APF category includes filtering facepieces, and half masks with elastomeric facepieces. 4The Company 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. 5These 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, the Company 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)(ii).
17 of 18 Respiratory Protection Program Revised: 08/08/2019
< THIS PAGE INTENTIONALLY LEFT BLANK >
18 of 18 SPILL PREVENTION, CONTROL AND COUNTERMEASURES (SPCC)
Awareness and Annual Refresher Training
Carl Thunem, Director HSE May 8, 2017 What is SPCC?
Spill Prevention, Control, and Countermeasure (SPCC) rule: Part of the Oil Pollution Prevention regulation (Implemented in 1974 under the authority of the Clean Water Act) Purpose: prevent oil from reaching navigable waters and adjoining shorelines, and to contain discharges of oil.
Oil (or oily product) of any kind or in any form, including, but not limited to:
Petroleum based oils and greases, including petroleum, condensate, produced water, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, and oil mixed with wastes other than dredged spoil.
Fats, oils, or greases of animal, fish, or marine origin; and
Vegetable oils, including oils from seeds, nuts, fruits, or kernels.
What are “navigable waterways”?
Defined as water of the United States, and all tributaries, and all adjacent waters, including the 100-yr flood plain.
Examples: lakes, rivers, streams (including intermittent streams), dry creek beds, ditches, wetlands and tributaries to these. SPCC Applicability
SPCC regulations apply to owners and operators of non-transportation related facilities (i.e. those not otherwise regulated by DOT) that stores, processes, refines, uses or consumes oil. Some examples of covered facilities and operations include: Onshore and offshore oil well drilling facilities; Onshore and offshore oil production facilities (including separators and storage facilities); Oil refining or storage facilities; Industrial, commercial, agricultural, or public facilities using or storing oil; Loading racks, transfer hoses, loading arms, and other equipment; Vehicles and railcars used to transport oil exclusively within the confines of a facility; and Pipeline systems used to transport oil exclusively within the confines of a facility. SPCC Applicability
SPCC rule applies if the facility:
Stores 1,320 gallons of oil in aggregate above-ground storage or has 42,000 gallons of completely buried oil storage capacity (not counting containers <55 gallons); and
Has a “reasonable expectation of an oil discharge” to a waterway or adjoining shoreline.
Not Counted: less than 55-gallons
30 gals
5 gals
Permanently Closed (OOS) tanks/containers are not counted if: 55 gals All liquid has been removed All lines/piping have been disconnected and blinded All valves have been closed and locked Signs have been posed on the container stating that it is permanently closed and noting the date of closure SPCC Applicability
What is a “reasonable expectation of an oil discharge” to a waterway or adjoining shoreline? Is there a defined flow pathway (i.e. drainage ditch, storm drain, etc. to waters of the US? This is a good start in determination (but don’t assume). Consider proximity to water, land contour, drainage, rainfall/storm water runoff, but exclude manmade features such as secondary containment, dikes and impoundments from your determination Recommended to document determination if you conclude you are not subject to the rule; very few locations actually get out of this rule. SPCC Applicability
SPCC is regulated by the EPA and is not delegated to the states. However, some states may have their own regulations that may or may not be more stringent than the federal regulation.
For example, Louisiana has an SPC regulation. The minimum aboveground storage capacity at which the SPC regulations apply is:
1,320 US gallons for two or more individual aboveground containers in aggregate within a common storage area; or
660 US gallons for an individual container for regulated materials that are not oil.
Some states and jurisdictions have lower reportable quantities for reporting spills. Requirements of the SPCC Rule
Requires certain facilities to develop and implement a written site-specific SPCC Plan to address:
Containment and procedures to PREVENT oil discharges;
Proactive CONTROL measures to keep an oil discharge from entering navigable waters of the US or adjoining shorelines (containment); and
Effective COUNTERMEASURES to contain, clean up, and mitigate any oil discharge that affects navigable waters of the US or adjoining shorelines (spill response measures). SPCC Plan
SPCC Plan addresses: □ The type of oil in each container and its storage capacity; (40 C.F.R. § 112.7(a)(3)(i)) □ Discharge prevention measures including procedures for routine handling of products (loading, unloading, and facility transfers, etc.); (40 C.F.R. § 112.7(a)(3)(i)) □ Discharge or drainage controls such as secondary containment around containers and other structures, equipment, and procedures for the control of a discharge; (40 C.F.R. § 112.7(a)(3)(ii)) □ Countermeasures for discharge discovery, response, and cleanup (both the facility’s capability and those that might be required of a contractor); (40 C.F.R. § 112.7(a)(3)(iii)) □ Methods of disposal of recovered materials in accordance with applicable legal requirements; and (40 C.F.R. § 112.7(a)(3)(iv)) □ Contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with whom you have an agreement for response, and all appropriate federal, state, and local agencies who must be contacted in case of a discharge as described in section 112.1(b). (40 C.F.R. § 112.7(a)(3)(v)) SPCC Plan
The SPCC Plan must be maintained at the facility if manned 4 hours per day or more, or at the nearest field office for unmanned facilities and must be available and provided to agency personnel upon request. Plan must be certified by a licensed PE unless site meets Tier I or II criteria to self certify □ Self-certify if the facility’s total aboveground oil storage capacity is 10,000 gallons or less and the facility has not had : 1) a single discharge of 1,000+ into waterway; or 2) two discharges of 42+ gallons into a waterway in any 12 month period. Plans must have a signed statement of Management Approval Plan must contain a facility diagram which includes all fixed containers and identifies mobile/portable container “areas” – [further discussed later] SPCC Plan
SPCC Plan must include the following spill prevention measures: □ Use containers suitable of the oil stored □ Identification of contractor(s) that can help clean up a spill □ Provide effective secondary containment as required [discussed later] □ Routine Inspections [discussed later] . Operations should be conducting and documenting these inspections monthly and submitting the documentation to the Environmental Dept., unless the plan states otherwise. Plan Review and Amendments [40 CFR 112.5]
Must be reviewed/evaluated at least every 5 years. Amendments are required to be made within 6 months and implemented ASAP but no later than 6 months after the amendment (except that LDEQ SPC rules require amendments prior to or concurrent with the facility modification): □ Technical amendments must be made and certified by PE when: . Commissioning or de-commissioning of containers . Reconstruction, replacement, or movement of containers . Reconstruction, replacement, or installation of piping systems . Construction or demolition that might alter secondary containment structures . Changes of product or service . Revision of standards operation or maintenance procedures □ Non-technical amendments must be made when: . Change in the name or contact information of the individuals named in the plan . Change in the name or contact information of spill response or cleanup contractors Operations personnel must contact HSE immediately upon knowledge of activity that will require an amendment as described above. Personnel & Training
Oil-handling personnel must be trained in (i.e. all plant/field personnel): □ Operation and maintenance of equipment to prevent discharges □ Discharge procedure protocols □ Applicable pollution control laws, rules, and regulations □ General facility operations □ Contents of SPCC Plan Each facility must designate a person who is accountable for discharge prevention and who report to facility management. □ This will normally be the or Operations Manager, Superintendent or Foreman who may in turn delegate the task Personnel & Training
At least once per year, hold Discharge Prevention Briefings for oil-handling personnel to assure adequate understanding of the SPCC Plan for that facility. Briefings must highlight and describe:
Location of SPCC Plan
Review oil handling procedures including loading/unloading procedures [Group Discussion]
Review spill response procedures and locations of spill response materials [Group Discussion]
Discuss roles and responsibilities for spill response [Group Discussion]
Review locations of drains and storm sewers that need to be protected [Group Discussion]
Discuss any discharges or failures in the past 12 months [Group Discussion]
Record Retention = 3 years Secondary Containment [40 CFR 112.9(c)(2)] General Containment: Containment where sizing is not dictated by the rule provisions. Sized to address the most likely oil discharge from any part of a facility where oil is handled. Examples: spill kits, absorbent material, drip pans, curbing, etc. Specific Containment (Sized Containment): Containment where sizing is dictated by specific rule provisions. Sized to address the worst case discharge for bulk containers and loading racks. General Secondary Containment
General Containment requirements apply to: □ Oil-filled equipment: transformers, pumps, process equipment, heat transfer systems, hydraulic systems, lubricating systems, gear boxes, circuit breakers, etc. □ Transfer areas: piping runs/racks, manifolds, flow & intra facility gathering lines, truck loading/unloading areas (not to be confused with loading/unloading racks), etc. No specific-sized volume requirement. Sizing based on typical spill size, not container size. Alternative to the general containment requirements, if a facility meets eligibility criteria, it may prepare an oil spill contingency plan and a written commitment of manpower, equipment and materials One of the following General Containment systems or its equivalent should be used at a minimum for these facilities:
□ Impervious dikes, berms or retaining walls □ Curbing or drip pans □ Sumps and collection systems □ Weirs, booms, or other barriers □ Culverting, gutters or other drainage systems □ Retention ponds, spill diversion ponds □ Spill kits □ Sorbent materials Truck Loading/Unloading “Area” vs “Rack” Specific Secondary Containment
Specific Secondary Containment (aka “Sized Secondary Containment”) applies to: □ Bulk storage containers, including but not limited to condensate tanks, produced water/oily water tanks, etc. □ Tank truck loading/unloading racks (tank truck loading/unloading “areas” only require general containment) Bulk storage containers containment: □ Sized to the capacity of the largest single container with sufficient freeboard to contain precipitation (typically calculated as largest container plus freeboard to contain precipitation from a 25-year, 24 hr.. storm event, or 110% of the largest container – though 110% may not always be acceptable). □ Sized containment could be an earthen berm, concrete dike, other lined containment, earthen remote impoundment, etc. For loading/unloading racks containment: □ Sized to the volume of the single largest compartment on tank truck, rail car, etc. Inadequate Containment (common violations)
Containment is full or partially full of storm water (i.e. was not drained after rain event) Equipment, pipes, additional tanks, etc. not original to the plan or included within containment calculations is located within the containment ANYTHING that displaces volume may inhibit the containment from providing sufficient capacity. Vegetation growth that compromises integrity or inhibits inspection Containment integrity failure: □ Holes, leaks, tears, cracks, etc. in containment poly and/or concrete barriers □ Eroded dirt/caliche berms – may have naturally eroded or eroded due to foot or vehicular traffic. Inspections, Tests, and Records [40 CFR 112.7(e)] Visual Inspections each shift: □ Routine, informal inspections (undocumented) during each shift to include observations for the condition, maintenance needs, and visible leaks. □ Immediately initiate proper corrective action. Inspect containment after each Rainfall Event [drainage discussed later] Monthly Documented Inspections (unless plan states otherwise): □ Utilize checklist in SPCC Plan Annual Documented Inspections: □ Utilize checklist in SPCC Plan Integrity testing shall be performed in accordance with the appropriate API standard and shall be implemented by operations as part of the facility’s Preventative Maintenance (PM) program. Maintain copy of records with the SPCC Plan (Record Retention Requirement = 3 yrs.). Facility Drainage [40 CFR 112.9(b)]
Containment drains must remain closed except when draining uncontaminated storm water. After rainfall events, promptly inspect and drain or dispose of storm water: □ Prior to discharge, inspect for sheen. □ Remove accumulated oil and return it to storage or dispose of it in accordance with legally approved methods. □ Drainage operations must be supervised at all times (do not walk away while drain is in the open position). □ Document each discharge of storm water (Record Retention = 3 years) . Keep in an accessible file. Inspect field drainage systems (such as drainage ditches or road ditches), and oil traps, sumps, skimmers, etc. for accumulation of oil: □ Regularly scheduled intervals □ Remove any accumulated oil Drainage Discharge Form can be found in the SPCC Plan. Discharge Prevention
Maintain appropriate containment in good condition at all times. Keep it free of vegetation that can compromise imperviousness and inhibit inspections. Address deficiencies immediately. Keep general containment supplies such as spill kits, sorbent material, etc. sufficiently stocked at the facility and replace it promptly upon use Keep containment drains closed except during supervised drainage Immediately mitigate spills Make materials and equipment for containment and clean-up readily available Ensure a 24-HR emergency response contractor is available for containment and clean-up for significant events. Keep the contact information current. Conduct all routine inspections (per shift, monthly, annually, after rainfall events). Address deficiencies immediately. Hi-level alarms and/or shutoff devices, direct visual gauges, etc. are utilized while filling tanks and loading trucks. Personnel must be present. Repair equipment and clean up any signs of visible discharges from any equipment promptly. Facility Security Requirements and Recommendations
Master flow and drain valves on tanks must be secured in the closed position when not in use (40 C.F.R. § 112.7(g)(2)) Pump starter controls must be locked and in a location only accessible to authorized personnel (40 C.F.R. § 112.7(g)(3)) Loading/unloading connections must be capped when not in service (40 C.F.R. § 112.7(g)(4))
If the facility is in a residential area within city limits, the following are recommended: Facility must have adequate lighting to detect and cleanup spills at night and deter vandalism (40 C.F.R. § 112.7(g)(5)(ii)) Facility must be fenced unless attended 24-hours/day (40 C.F.R. § 112.7(g)(1)) Loading/Unloading Rack Procedures
Secondary containment must be provided for the capacity of largest compartment of tank car or tank truck (40 C.F.R. § 112.7(h)(1)) Provide an interlocked warning light or physical barrier system, warning signs, wheel chocks, or vehicle break interlock system to prevent vehicles from departing prematurely (40 C.F.R. § 112.7(h)(2)) Prior to filling and departure of any tank car or tank truck, closely inspect for discharges the lowermost drain and all outlets of such vehicles, and if necessary, ensure that they are tightened, adjusted, or replaced to prevent liquid discharge while in transit. (40 C.F.R. § 112.7(h)(3)) Utilize electronic and/or visual tank gauges to monitor the quantity in the tanks Driver must be present at all times during all loading and unloading operations Connections for all loading/unloading operations are sealed when not in use Place drip pans under the hose connections to contain any dripping product that may occur during the transfer operation Transfer Operations, Piping & Pumping [112.8(d)]
Buried piping installed or replaced after 8/16/2002 must be coated, wrapped, and cathodically protected or satisfy the corrosion requirements under 40 CFR parts 280 or 281 Exposed buried line must be inspected for deterioration and corrected as appropriate Out of service pipes must be labeled as to origin and capped or blank-flanged Pipe supports must be designed to minimize corrosion and abrasion and allow for expansion Aboveground piping, valves, and appurtenances must be inspected regularly and the general condition assessed Buried pipes must be leak tested at the time of installation, modification, construction, relocation or replacement Pipes must be protected from vehicular traffic with warnings, signs or physical barriers Brittle Fracture Evaluation
Evaluate brittle fracture risk and take appropriate action if the container undergoes the following: □ Repair □ Alteration □ Reconstruction □ Change in service Refer to API Standard 653 or other appropriate standard Spill Procedures
The facility SPCC Plan includes Spill Procedures, and may also include an Emergency Response Action Plan (ERAP) or Emergency Response Plan (ERP) □ Know the plan. Don’t wait until an incident to familiarize yourself with the procedures. Emergency Response Supervisor (Area/Facility Foreman) is responsible for all activities by facility personnel during an emergency event and will determine the level or response by an outside contractor. Safety will always remain the first and highest priority At no time will an employee assume an unreasonable risk to deal with an emergency. An unreasonable risk exists when: □ The task exceeds the physical abilities of the individual □ The individual is not properly trained to complete the task □ The individual does not have adequate experience to complete the task □ The individual does not have the proper PPE and safety equipment to complete the task □ Company procedures prohibit attempting the task Spill Response Procedures RECEIVING INFORMATION REGARDING A SPILL, RELEASE, FIRE, EXPLOSION OR OTHER EMERGENCY AT UNMANNED FACILITIES In the event the company receives notification of a potential emergency by a non-Company employee, document the following information: □ Name and contact info of the caller □ Name and address or location of the emergency □ Date and time the event began/ended, or if it’s ongoing □ Extent of any injuries, fatalities, or property damage □ Nature of the emergency and affected facilities □ Extent that any public officials have been contacted □ Any other information that may be helpful Advise non-Company employees to: □ Evacuate and warn other to evacuate to a safe area if leaking gas is involved □ Avoid or eliminate possible ignition sources □ Not to attempt to put out fire or operate Company valves/equipment □ The Company or response contractor will arrive soon in order to bring the emergency under control Follow Initial Incident Reporting Procedures Spill Response Procedures – Response Actions
Notification □ Begin notification as soon as safe & practicable (concurrent with other response actions if possible) Secure the area □ Remove ignition sources, if applicable □ Establish and maintain a perimeter or safe zone □ Restrict access; only authorized personnel and emergency responders with appropriate PPE for worst case scenario allowed access □ Evacuate, if necessary □ Prohibit entry into vapor cloud or area with a hazardous atmosphere (≥ 10% of the LEL) Identify problem □ Identify scope and nature of the problem, including recognition of all hazardous materials involved, the type of facilities involved and any collateral exposures □ Mobilize additional responders and resources as necessary Spill Response Procedures – Response Actions
Hazard and risk assessment □ Assess the hazards □ Utilize gas detection equipment to determine the extent of any vapor cloud or hazardous atmosphere □ Evaluate the level of risk □ Determine appropriate PPE □ Establish an action plan to bring release under control □ Re-assess hazards and risks as often as needed and immediately when there is a change in condition(s) that impact the current action plan □ If appropriate, utilize pre-planned emergency procedures (various ERP’s – 195 ERP, 192 ERP, Plant EAP, etc.) System shut down, isolation and pressure reduction □ Isolate the emergency as soon as it is safe to do so – may include shutting down pipelines, plants, pumps, isolating valves, blowing down pressure, etc. □ Consider use of portable flares for blowdowns, if appropriate (i.e. populated areas) Spill Response Procedures – Response Actions
Leak/spill containment □ Assess exposures to sensitive areas and contain discharges as soon as it is safe to do so since even minor leaks/spills can evolve into a major spill as liquids inside the pipe or container continues to bleed out, as spills are impacted by rain fall, or drainage systems, etc. □ If a discharge has not reached a waterbody, the following control methods should be considered: . Deploy sandbags and absorbent socks down-gradient from the discharge source, or erect temporary barriers to prevent any discharge from flowing towards a waterbody and to prevent further contamination . Implement land based response actions (countermeasures) such as digging temporary containment pits or trenches to prevent any discharge from entering a waterbody or to prevent further contamination . Utilize storm sewer or manhole dams, as necessary . Deploy absorbent sock and sorbent material along backlines to prevent discharges from entering a waterbody . Deploy floating booms immediately downstream from the release point as a back-up measure in the event the discharge reaches the water Spill Response Procedures – Response Actions
Leak/spill containment continued… □ If a discharge has reached a waterbody, the following control methods should be considered: . Contact Emergency Response Clean-up Contractor immediately . Deploy floating booms immediately downstream from the release point. . Deploy additional floating booms, as necessary, downstream should the first fail. . Deploy protective booming measures for downstream receptors that may potentially be impacted by the discharge . Control flow on the ground by deploying sandbags and absorbent socks down- gradient from the source, or erect temporary barriers such as earthen berms to prevent further spread and contamination . Implement land based response actions (countermeasures) such as digging temporary containment pits or trenches to prevent further spread and contamination . Utilize storm sewer dams or manhole dams, as appropriate Spill Response Procedures – Response Actions
Clean-up □ Begin clean-up as soon as possible to prevent further contamination. Dependent upon conditions, a third-party may be contracted to perform clean-up activities □ Collect all debris in properly labeled waste containers □ Dispose of contaminated material in accordance with all applicable laws and regulations using a licensed waste hauler and disposal facility, after appropriately characterizing and profiling the material for disposal Repairs □ Proceed with repairs in accordance with applicable policies and procedures Event logs/documentation and investigation □ All company employees involved in an event should do their best to maintain a log of events to later be utilized during event investigation. Each event is different and you can’t predict if/when an event will happen. Know your site specific Emergency Plans before an emergency occurs. Use good judgment and always put safety first. Internal Notification/Reporting
All releases, spills, injuries, near misses, emergencies and potential emergencies must be reported to your immediate supervisor and HSE Lead or Director. Releases & Spills: Maintain records of all unauthorized releases and spills, regardless of quantity, utilizing the Initial Incident Report Form. In addition to the internal notification report, ensure HSE is notified of unauthorized releases and spills so that required follow-up and written reports are submitted to regulatory agencies and our insurance carriers timely. Federal Agency Notification/Reporting
National Response Center (immediate verbal notification): □ Pipeline “Incidents” and “Accidents” as defined by 49 CFR 192 & 195 □ Spills that impact a waterway (i.e. produce film or sheen) □ RQ exceedances of Hazardous Substances (unless CERCLA Petroleum Exclusion applies) . CERCLA Petroleum Exclusion: excludes crude oil, fractions of crude oil, natural gas, natural gas liquids, liquefied natural gas and their indigenous substances prior to the refining process. EPA: □ Written report to EPA and state agency within 60 days if: . Discharged more than 1,000 gallons into waterway or adjoining shoreline . Discharged 42+ gallons in two events within any 12 month period OSHA: □ Within eight (8) hours after the death of an employee from a work related incident ;or □ Within twenty-four (24) hours after the in-patient hospitalization of one (1) or more employees or an employee’s amputation or an employee’s loss of an eye, as a result of a work related incident. State/Local Agency Notification/Reporting Conclusion
Questions??? Contact me anytime if you have any HSE or regulatory questions.
Carl Thunem Director – HSE 972-795-9869 [email protected] Louisiana Notification/Reporting
Louisiana State Police: notify immediately (within one hour) of any emergency condition. Emergency Condition - any condition which could reasonably be expected to endanger the health and safety of the public, cause significant adverse impact to the land, wa ter, or air environment, or cause severe damage to property. □ Ops Manager reports unless contact has been made with EHS to coordinate the notification. Additionally, All releases and incidents involving a regulated hazardous material must be reported immediately to LEPC and LSP if the release or incident meets (1) or more of the following conditions: □ Release directly causes an injury requiring hospitalization or any fatality □ Release results in a fire or explosion & could affect public safety beyond the facility boundary □ Release exceeds the RQ during any continuous 24 hr. period when that RQ could escape beyond the facility □ The incident, accident or cleanup within a facility could affect the public safety beyond the facility boundary (ex. facility evacuating personnel) □ A protective action beyond the facility has been initiated Common RQ’s listed on the emission event calculation spreadsheet Written reports due within 5 days Louisiana Notification/Reporting
LEPC & SERC: immediate verbal notification if RQ is exceeded for a CERCLA hazardous substance or an extremely hazardous substance. Follow-up reports required. □ Ops Manager reports unless immediate contact can be made with EHS to coordinate the notification. □ SERCs: Louisiana = LSP Texas = TCEQ □ LEPC: for operating areas, LEPC is listed by Parish/County LDEQ & TCEQ: Report within 24 hours if RQ is exceeded or if discharge reaches waterway. Follow-up reports required. □ Contact EHS immediately to coordinate reporting GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM SHORT SERVICE EMPLOYEE PROGRAM
1) PURPOSE
Minimize the risk of injury to a Short Service Employee (SSE) through recognition of SSE and implementing these policies and procedures.
2) POLICY
a) Requirement:
i) A newly hired employee, an employee promoted to a new position in the Company, or an employee relocated to a new site, each of whom have not yet demonstrated competence of Company safety policies for their work environment, regardless of prior experience, shall be designated as an SSE.
ii) A mentor will be assigned to each new SSE.
b) SSE Crew Structure:
i) SSE’s shall not be supervisors.
ii) No more than 50% of each crew can be SSE’s.
3) RESPONSIBILITY
a) Management shall comply with the requirements of this program.
b) Mentor shall:
i) coach and provide a high level of direction in the form of hands-on suggestions and other performance feedback.
ii) review the job hazards and safety requirements prior to each critical task (injury potential) to be performed that day.
iii) observe the SSE for application of safety techniques, policies, procedures applicable to SSE’s work.
c) SSE shall:
i) perform only assigned/authorized tasks.
ii) make efforts to understand and apply those safety requirements applicable to his/her job or work.
1 of 2 GEO FOSSIL FUELS, TABULA RASA ENERGY and PERDURE PETROLEUM SHORT SERVICE EMPLOYEE PROGRAM
iii) ask their mentor, supervisor or other knowledgeable person questions if they do not understand any aspect of the safety techniques, policies, or procedures applicable to his/her job or work.
4) DEFINITIONS
a) Short Service Employee (SSE) – A newly hired employee, an employee promoted to a new position in the Company, or an employee relocated to a new site, each of whom have not yet demonstrated competence of Company safety policies for their work environment regardless of prior experience. SSE’s are employees who, according to accident statistics, are more likely to experience an accident involving a work related injury or illness.
2 of 2 APPENDIX 2: FORMS
• PERDURE TRP INITIAL INCIDENT REPORT FORM • NEAR MISS INVESTIGATION FORM • PERDURE_TRP_DRIVER’S VEHICLE ACCIDENT REPORT • MVA (Motor Vehicle Accident) GUIDE • MVA GUIDE WITNESS STATEMENT REPORT • LOCK-OUT / TAGOUT FORM • PERDURE TRP SAFE WORK PERMIT_JSA • SAFETY MEETING ATTENDANCE LIST INITIAL INCIDENT REPORT FORM
AREA: ALLEN HOUSTON LA VETA PANHANDLE PERMIAN SHIDLER LAB STATE: COUNTY:
FACILITY / WELL: ______INCIDENT TYPE: INJURY/ILL SPILL/RELEASE FIRE/EXP PROPERTY DAMAGE NEAR MISS SECURITY INCIDENT DATE: INCIDENT TIME: AM/PM REPORTED BY: DATE: TIME: PERDURE/TABULA RASA/GFF SITE SUPERVISOR: ____ PHONE:______ON LOCATION AT TIME OF INCIDENT? YES NO CONTRACTOR SITE SUPERVISOR/TOOL PUSHER: ______CONTRACTOR: PHONE:
INCIDENT DESCRIPTION:
INITIAL ACTIONS:
PERSONNEL ON LOCATION / WITNESSES: NAME EMPLOYER PHONE E-MAIL INJURY CATEGORY: NEAR MISS FIRST AID RECORDABLE LOST TIME
INJURED PERSON: EMPLOYER:
INJURIES/PART OF BODY:
TRANSPORTED TO MEDICAL FACILITY? YES NO FACILITY NAME:
IF YES, HOW TRANSPORTED:
IF NO, STATE REASON:
SPILL/RELEASE: GPS COORD./LAT. ______LONG. ______
INITIAL ESTIMATE OF VOLUME RELEASED:
OIL (BBL) GAS (MCF) WATER (BBL) OTHER (GAL)
CHEMICAL TYPE IF OTHER
CONFINED WITHIN SECONDARY CONTAINMENT? YES NO CONTAINED ON LOCATION? YES NO
I IMPACT TO: SOIL WATER AIR LANDOWNER PROPERTY PUBLIC PROPERTY
COMMENTS: ______
RECOVERY STATUS: IN PROGRESS COMPLETE VOLUME RECOVERED (GAL)
MEDIA/PUBLIC ATTENTION GENERATED/LIKELY? YES NO FIRE/LAW ENFORCEMENT RESPONSE? YES NO
REGULATORY AGENCIES / AUTHORITIES NOTIFIED: AGENCY DATE/TIME CONTACT PERSON (NAME/TITLE)
PERDURE PETROLEUM/TABULA RASA/GFF PERSONNEL NOTIFIED: NAME TITLE DATE/TIME HOW NOTIFIED NEAR-MISS REPORT
Geo Fossil Fuels, Tabula Rasa Energy and Perdure Petroleum
1. Name of Person involved (Last, First, Middle Initial) 2. Title/Position of Person Involved
3. Name of Person Completing Form (Last, First, Middle Initial) 4. Title of Person Completing Form
5. Department 6. Contact Phone Number
7. Witness Name (Last, First, Middle Initial) 8. Witness Phone Number
9. Date & Time of Incident 10: Near-Miss Location – Site of Incident (Building name, Room No., Stairs, Hallway, etc.) If outside of building, give location in reference to nearest building. Date: ______
Time: ______AM/PM ______
11. Near-Miss Description (Describe fully the protocol/procedures being followed including all substances, equipment, and machinery being used which was related to the near-miss Use additional sheets if necessary)
______
______
______
______
12. Personal Protective Equipment (PPE) Used (if applicable)
13. Severity – Circle the level of severity which you feel could occur if such an incident evolved (Example: High = fatality, permanent disability, high dollar loss; Medium = temporary disability, some dollar loss; Low = minor or no injury, no lost dollar. Consider such factors as physical injuries, damage to equipment or property, and environmental impact) HIGH MEDIUM LOW
14. Probability – Circle the level of probability that a person or property may be exposed to a similar situation, and that required hazards or system failures may be present or likely. (Example: High = tasks occur frequently and by numerous individuals; Medium = tasks occur on a regular basis by certain individuals; Low = tasks occur infrequently by few individuals. Also consider such criteria as complexity of the system, latent and human factors, etc.)
HIGH MEDIUM LOW
15. Corrective Actions (what should be done or has been done to prevent recurrence of this incident? E.g. employee training, change of procedures, purchasing of equipment, etc.)
______
______
______
______
______
______
16. Miscellaneous Information (Provide any other information or recommendations which you feel are pertinent to the incident)
______
______
______
DRIVER'S REPORT OF MOTOR VEHICLE ACCIDENT
1. WHERE ACCIDENT OCCURRED 2. WHEN ACCIDENT OCCURRED
MONTH 0AY YEAR COUNTY CITY HOUR Road or Stree1 on which Accidenl Occurrod �� tHl9hw.;1y Number. u.s o, state, 1t no r>"W' way numt>et iden111y road by nam•I f"V�B�.13-0 ,._.VEHICLES At lntorsecilon with F 010 POLICE OFFICER 1 Yes (Numt,et{Cl,ch> 1) or Na.me 01 lnlarsectmg �hway or Su-eol) j' -· II-- ,.,...... , ..,T? 2 .,_ 11 no1 a, Intersection OR NSEWof Was 1ramc citation 1ssued to 0rtver # 1 Feet MIios (Ne&ro&1 H1gl"lwoy, 'Sttee1, Br1<1ge, or Other Lanomark.) Veg,.., ..:... -r-, MARK POINT OF CONTACT #1 3. VEHICLE NUMBER 1 • YOUR VEHICLE
COMPANY Location: ADDRESS
DRIVER'S NAME (LAST, FIRST, MIDDLE) DRIVERS LICENSE NO. and STATE F VEHICLE LICENSE No. and STATE b b I IA VEHICLE MAKE I YEAR I MODEL&TYPE IDENTIFICATION NUMBER• SERIAL MARK POINT OF CONTACT #2 4. DRIVER NUMBER 2 • OTHER DRIVER • OR PEDESTRIAN DA1/ 0 DRIVER'S NAME (LAST, FIRST. MIDDLE) BIRTH MO. YEAR DRIVERS LICENSE NO. I STATE 1.MALE / I 1 OPED 2.FEMALE STREET ADDRESS CITY I COUNTY OF RESIDENCE I STATE Fb b I IA 5. VEHICLE NUMBER 2 • OTHER VEHICLE OWNERS NAME ADDRESS USE ATTACHED PAGE FOR MORE DETAILED DESCRIPTION OF DAMAGE VEHICLE MAKE YEAR MO0EL&TYPE VEHICLEUCENSENUMBER•STATEANDYEAA I Add additional pages for more vehicles? Insurance Co and Policy # Wostraffi: CIJaDon ISSU8CI 100.-IYef112? Yes □ No □ Yes □ No □ I SEAT SEAT EJEC IN VEH 6. LIST PERSONS INJURED NO BELTS JURY AGE SEX ING TION NAME ADDRESS
DESCRIBE INJURIES
NAME ADDRESS
DESCRIBE INJURIES
NAME ADDRESS
DESCRIBE INJURIES
DESCRIBE DAMAGE TO PROPERTY OTHER THAN MOTOR VEHICLES I OWNER'S NAME I OWNER'S ADDRESS
Police agency that investigated accident:______
Additional comments:______--- -·------DIAGRAM WHAT HAPPENED -� --· ------INSTRUCTIONS . ··. . - ---.. 1. Follow dotted lines to draw ...... -. --. . . outline of roadway a1 place ot ... - - . - . accident ·-- . . . •: ... -. ------.. . : . . .. ·. -. - . . . . 2. Number each vehicle and show ...... · . -- . direction of travel by arrow : 1 2 � ---· :·;• �------. --. --... --. ---... -. --....- ... --. ---�--= ....• ----. --. -. - ·. Use solid line to show path before accident
dotted
4. Show pedestr-ian by; ---0 DESCRIBE WHAT HAPPENED (Refer to vehicles by number): 5. Show railr'oad by: CD 6. Show utillty poles by: 7. Show motor-cycle by: -e--e- PLEASE INDICATE DAMAGE TO VEHICLE(S)
SAFE WORK PERMIT – JOB SAFETY ANALYSIS (JSA) & TAILGATE SAFETY MEETING JSA 20180321
Location/Jobsite: Equipment Line/ID: Contractor: EMERGENCY CONTACT (Radio Channel, 911 or Phone No.): Permit Issued Transferred Completed Description of work to be Date: performed: Time: Formal Job Plan Reviewed: Yes NA GPS: Lat: Long: Address:
Hazard Assessment (Check Box if Present) Required PPE Atmospheric Monitoring NA (Subsequent monitoring results will be recorded on back of Field Copy) Materials / Chemicals / Toxins Safety Glasses Safety-Toed Footwear Face Shield SDS to be made available upon request Hearing Protection Hard Hat FRC Initial only Periodic Continuous (check only one)
NGL / HVL Crude Oil H2S Gloves – Leather Arc Flash Gear Boots – Rubber Document atmospheric readings every: hours minutes CO Chlorine Asbestos Harness w/ Layard Tyvek/Chemical Suit Acid Suit Monitor Type: Serial Number: Acid / Caustic Natural Gas Benzene Harness w/ Life Line Splash Apron Slicker Suit Calibration Date: Calibrated By: Refined Products Nitrogen Lead Respirator – APR Goggles Flotation Device Function/Bump Test: Yes Tested By: NORM Other: Supplied-Air Respirator Chemical Gloves Personal Monitor Initial Test For: Results Time Tested: Initials of Tester: Physical Hazards Other(s): Electrically Insulated Gloves High Visibility Vest Oxygen Overhead Work Heat/Cold Electrical NA Safety Precautions LEL
Rotating Equipment Pinch Points Walking/Working Surfaces GFCI(s) Ladder Tie-Off Barricade(s) H2S Power Tools High Traffic Area Vehicles/Heavy Equipment Attendant/Hole Watch Spill Containment Warning Signs CO Corrosives Fall Potential Overhead Power Lines Other(s): Electrical Grounds and Boundaries Other Noise Lifting/Rigging Underground Utility NA Fall Protection NA Hot Work Poor Lighting Severe Weather Working Over Water Rescue Services Available Man Lift On Site Other(s): (Fire watch and periodic or continuous air monitoring required) Respiratory Opening of Process Utilities that may be NA Confined Space Nature of Work: Welding Cutting Grinding Pipe and/or contacted by cutting or Other(s): Does the work require entry into a confined space? Equipment drilling Yes No If YES, entry must follow requirements of Confined Space Practice Other spark/flame producing activities: Forms of Hazardous Energy Has the space been re-classified by removing potential hazards and is Yes No Control center/room notified? Contact: LO/TO Verified If any are checked, follow LO/TO (Energy Isolation) Practice This documented on the Confined Space reclassification form? Air monitored within 35 ft. of hot work? (include above and below) If re-classified to non-permit, has the reclassification been verified Electrical < 600 volts Electrical ≥ 600 volts Fluids & Gases Yes No And is the space still hazard free? (required daily) Equipment LEL 0 – 10 % (>0% requires Supervisor and Safety approval with continuous monitoring) Hydraulic Steam Pressure NA Trench / Excavation All openings protected? (e.g., sumps, drains, sewers etc.) Does the work involve an excavation or trench? Pneumatic Mechanical Radiation Yes No If YES, work must follow requirements of the Excavation Safety Practice. All combustible material moved 35 ft. away, covered and/or wetted?
Other(s): Yes No Has a Daily Excavation Checklist been completed? Fire extinguisher(s) available? Does the work involve the use of non-intrinsically safe tools or equipment in a One Call # Fire watch dedicated? classified area? Yes No If YES, complete atmospheric monitoring section. Fire watch assigned for ½ hour after work completed?
Approvals Comments: Authorized Representative: Print: Sign:
Authorized Representative (Transferred To): Print: Sign:
Contractor Representative: Print: Sign: Retention Schedule: 1 Year or until a documented review has been completed. Page | 1 SAFE WORK PERMIT – JOB SAFETY ANALYSIS (JSA) & TAILGATE SAFETY MEETING JSA 20180321
JOB SAFETY ANALYSIS (JSA) Job Task(s) Risk Level Hazard(s) Engineering or Administrative Controls PPE List procedures that apply. List individual task. Use Risk Matrix below. Identify hazards associated with task. List appropriate engineering controls. List appropriate PPE. List procedures or other administrative controls.
Page | 2 Additional Monitor Monitor Type: Monitor Type: Monitor Type: Monitor Type: Serial Number: Serial Number: Serial Number: Serial Number: Calibration Date: Calibration Date: Calibration Date: Calibration Date: Calibrated By: Calibrated By: Calibrated By: Calibrated By: Function/Bump Test: Yes Function/Bump Test: Yes Function/Bump Test: Yes Function/Bump Test: Yes Tested By: Tested By: Tested By: Tested By:
Atmospheric Test Results
Time O2 LEL % Toxin (CO, H2S, etc.) PPM Tested By
Designated Smoking Area (If not predetermined) Identify and communicate smoking areas:
Additional Emergency Information (If not predetermined) Identify and communicate muster/rally point and alarm system: Emergency Contact Numbers: (Identify 911 address, GPS coordinates, physical address, nearest intersection or cross street to job site.)
Contractor Contact: Phone:
Nearest Hospital/Clinic: Phone: Nearest Fire Department: Phone: Nearest Police Department: Phone: Nearest Ambulance: Phone:
Retention Schedule: 1 Year or until a documented review has been completed. Page | 3 Tailgate Safety Meeting – Personnel Accountability Log Topics Discussed: Required PPE from above Job Tasks Hazards Involved Energy Sources Corrective Actions Name (Print) Company Time In Time Out Time In Time Out
Retention Schedule: 1 Year or until a documented review has been completed. Page | 4 GEO FOSSIL FUELS, TABULA RASA ENERGY AND PERDURE PETROLEUM SAFETY MEETING ATTENDEE LIST
DATE: LOCATION:
TIME:
TRAINER:
SUBJECT:
NAME (print) LAST 4 DIGITS OF SOCIAL EMPLOYEE SIGNATURE SECURITY NO.