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DOW RESTRICTEDDOW RESTRICTED,Global Safety Standard Orientation,Confined Space Entry,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Scope: Requirements apply to all Confined Space Entries.Definition: Confined Space: Any Space:With limited or restricted openings for entry and exit that is not designed for continuous occupancy, orWith a potential danger of solid, liquid, or vapor engulfment, orWhere the combination of poor ventilation and difficulty of access and escape poses a risk of a person being affected by one or more of the following:A fire or explosion.Oxygen deficiency or enrichment.Heat or coldFlowing solids and liquidsGases, vapors, mists or dusts.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Definition: Entry:The passing of ones face beyond the plane of an opening of a Confined Space, orThe passing of ones body part beyond the plane of an opening of a Confined Space with the intent to gain admittance to the Confined Space, or When a person enters an atmosphere projected from an opening in a Confined Space that contains physical, biological or chemical agents at or above applicable exposure limits (example: when nitrogen is projected from an opening of a purged vessel).General Exemptions:Servicing or working under vehicles with no possibility of engulfment or oxygen enrichment or deficiency.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Except when conducting rescue operations using the proper PPE, no person shall enter a Confined Space that is Immediately Dangerous to Life or Health (IDLH).Definition: Immediately Dangerous to Life or Health:Any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individuals ability to escape unaided from the Confined Space.Note: If there is any doubt whether or not IDLH conditions exist then an Industrial Hygiene Expert Partner should be contacted.For the purposes of this standard only, conditions such that, but not limited to any of the following:The concentration of a chemical is at or above the applicable 1990 NIOSH IDLH limit.The oxygen concentration is less than 17%.The concentration of a flammable is above 10% of the Lower Flammable Limit (LFL).Levels of ionizing radiation are at or above 100 mrem / 1.0 mSv per hour or the levels of non-ionizing radiation are at or above your applicable regulatory radiation limits.There are energy sources that have not been isolated that are capable of causing harm to which personnel could be exposed while doing the Confined Space Entry.The appropriate PPE is not be used and the previous contents pose an infection risk.The appropriate PPE is not be used and the noise level is above 105 dB(A) and/or 140 dB(lin).,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,All Confined Space Entries shall have:A Safe Work PermitA Confined Space Entry PermitA Confined Space Entry Operating ProcedureThe physical and toxicological properties of last contents and introduced materials will be reviewed to determine need for:PPERespiratory protection,Except where not effective (like an open diked area), forced or induced ventilation shall be provided.The person issuing the SWP will make sure that all entrants and Safety Attendants understand:The contents of the Confined Space Entry Operating Procedure.The scope and scale of the entryThe responsibilities of the Safety Attendant.The isolation of the energy sources.The hazards & safeguards.,General Requirements for all Confined Space Entries:,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,The person issuing the SWP shall ensure that emergency & rescue procedures are understood by Rescue Team.The continuous, two way communication method used to engage the Rescue Team will be tested.A safe and unrestricted means of entering and exiting the confined space will be in place.A Safety Attendant will be in place.,The continuous, two way communication method between the Safety Attendant and entrants will be established and maintained.The names and status (in or out) or all entrants will be documented.All rescue equipment (as identified in the emergency and rescue procedures in the CSE Operating Procedure) shall be in place and accessible.,General Requirements for all CSE (continued):,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,CSE Permits shall be approved:Confined Space Entries that are on the Facility / Work Groups list or routine, repetitive CSE shall be approved by the person who issues the CSE permit.All other CSE shall be approved by an authorized approver (in two groups, those CSE into oxygen deficient atmospheres and all other CSEs),DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Definition: Routine & Repetitive:Confined Space Entries that meet ALL of the following:They are done frequently enough such that the knowledge, skill and experience level of the people to enter the Confined Space, the Safety Attendant and the Personnel Issuing the Safety Work Permit is current and correct and does not need to be reviewed prior to entry. Frequent Confined Space Entries are those that are done with some regular repetition, such as weekly, bi-weekly, quarterly, etcFacility / Work Group Leadership is satisfied with the knowledge, skill and experience level of each specific person in the roles listed above with that specific Confined Space Entry.The hazards and safeguards are known and will not change.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Approval of Routine / Repetitive CSE:Leadership shall document the list of routine, repetitive CSEs for the Facility - and review this list annually.Leadership shall review the CSE Operating Procedure for these routine, repetitive CSEs annually.Leadership shall document the names of those people authorized to issue / approve CSE Permits for routine, repetitive CSEs - and review this list of names annually.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Approval of all other CSE:Leadership shall document the names of those people authorized to issue CSE Permits for CSEs - and review this list of names annually. (in two groups, those that approve CSEs into oxygen deficient atmospheres and all other CSEs)Leadership shall document the names of those people authorized to approve CSE Permits for CSEs - and review this list of names annually.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,The CSE Permit Approver shall:Conduct on-site inspection.Meet with all people to enter & Safety Attendant(s) prior to initial entry. (Person issuing SWP meets with people added to the job if the job is on-going.)Verify that the requirements of the standard are met.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,CSE Permit is cancelled and all work stopped until a new CSE Permit is issued if ANY of the following occur:i. The Safe Work Permit is suspended (See Safe Work Permit Suspension and Re-Authorization in the Safe Work Permitting Standard). ii. If a work stoppage occurs, and the Confined Space is left unattended.iii. If the conditions of the emergency and rescue procedures can not be met. (For example: Rescue Team Members or rescue equipment are otherwise engaged and can not be made available within the response time expected in the rescue procedure).,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,CSE Permit is suspended until re-authorized if:The Safe Work Permit is cancelled (See Safe Work Permit Cancellation in the Safe Work Permitting Standard). The safe conditions upon which the Confined Space Entry Permit was based have changed such that the hazards and safeguards identified on the original permit have changed. (For example: an evacuation, increased exposure levels, change in PPE requirement, etc.) Over 16 hours have elapsed since the Confined Space Entry Permit was issued.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Cleaning & Clearing:Physical, chemical & biological agents shall be cleared from the Confined Space to levels that are below IDLH prior to entry.If materials can not be cleared to levels below the applicable exposure guidelines, then appropriate personal protective equipment and respiratory protection shall be used.Personal protective equipment and respiratory protection shall not be used in place of cleaning, clearing and ventilation of a Confined Space.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Isolation of Energy Sources:An isolation of energy sources shall be in place to isolate the Confined Space from all potential energy sources prior to entry. (See Isolation Requirements in the Isolation of Energy Sources Standard.)Isolation methods used to ensure that materials have been relieved, drained, disconnected, restrained or otherwise rendered safe shall be limited to the following, in order of preferred method:Disconnect piping to provide an air gap in such a way that no material can enter the confined space.Installation of blinds, pancakes or spectacles as close as possible to the equipment. (Must be identifiable and distinguishable and appropriate for the chemical, temperature and pressure.)When the above two methods are not possible, then the use of double block and bleed with documented confirmation that the isolating devices are isolating the energy sources and secure from inadvertent operation.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Isolation of Energy Sources:The isolation shall:Isolate heat sources on externally heated vessels.Isolate and disconnect instrument lines, purges and other related connections.Shore the sides of pits, trenches and excavations that may be a hazard.Isolate electrical switchgear for moving or rotating equipment.Isolate electrical systems which may be a hazard.Mechanically block any rotating or moving elements which may be a hazard.Not block in any way the means of entry and exit to the Confined Space.Isolate any radiation and ultra violet light sources (See radiation isolation requirements in the Line & Equipment Opening Standard.),DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Ventilation shall be provided such that:The levels of airborne contaminants shall be at or below the levels determined during the initial entry permit conditions (initial hazard monitoring).The oxygen level does not drop by more than 1% from the level determined during the initial entry permit conditions, and does not enter a range where different respiratory protection requirements are needed.Air movers powered with non-breathing air supplies must discharge away from the Confined Space during entry.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Inert gas supplies (nitrogen) shall not be used to power air movers.Air movers must be grounded.When work inside could introduce an airborne contaminant (welding, painting, curing agents, etc.) then ventilation must be provided to prevent the level of introduced airborne contaminant from entering a range at which different respiratory protection requirements are needed. If not possible, then additional respiratory protection requirements must be determined.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,The required Personal Protective Equipment (PPE) and respiratory protective equipment must be determined based upon the hazards identified (for example: physical, chemical, biological, noise, radiation, etc) - including the hazards of the work being done and any agents introduced because of the work.These requirements must be documented and communicated.The use of all PPE must be in accordance with the Dow Personal Protective Equipment Standard, the Dow Hearing Conservation Standard and any site PPE requirements.The use of respiratory protective equipment must be in accordance with the Dow Respiratory Protection Standard and any site requirements.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Hazard Monitoring:Hazard Monitoring shall at least include:Oxygen content.Presence of flammable vapors (%LEL)The concentrations of materials that were previously contained or introduced into the space, when:These are chemicals of concern (on Relevant Agent list).Applicable exposure guidelines are set, andA monitoring method exists.Radiation when a radiation source is present.Temperature when the temperature has the potential to approach IDLH limits.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Hazard Monitoring:Be performed as close as possible prior to entry.Be performed with air movers shut off.When not using continuous monitoring, be repeated a sufficient frequency to ensure that acceptable air quality is maintained.Be repeated prior to re-entry, if the entry is interrupted.Include continuous %LEL monitoring if previous contents or introduced materials are flammable.Include continuous oxygen monitoring if necessary to verify that ventilation is adequate.For example: when there is the potential that the oxygen level could drop by more than 1% from the level determined during the initial permit conditions or could enter a range where different respiratory protection requirements are needed.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Hazard Monitoring:Done at all entry / exit points.Done inside the space at points that represent the air quality of the locations where the people to enter the space will be doing their work.Done at any point inside the space that could be impacted by or could impact the work being done (for example: when hot work at the top of a column could drop sparks to the bottom or when something could slough off the top and drop onto workers.)The specific hazard monitoring needs for each CSE shall be documented in the CSE Operating Procedure.The date, time and name of person performing monitoring and detected levels of hazards relative to their limits shall be documented on the CSE Permit.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Safety Attendant:A person, who has knowledge or how to recognize and emergency and initiate the emergency and rescue procedure, other than the people to enter, shall be present as the Safety Attendant.Additional attendants may be needed when the first attendant can not monitor all entrants, or when needed to monitor proper use of PPE (for example: a bottle watch for supplied breathing air).Shall not enter the space, expect in an emergency , and then only when it is called for in the emergency and rescue plan and additional help has already arrived.Shall not be assigned any additional tasks which will conflict with his/her duties.Will continually observe conditions inside and outside the space.Continually observe the integrity and proper use of PPE and respiratory protective equipment.Monitor the actions of the people inside the Confined Space and in the event of an injury, fire, gas release or other emergency: shut down the job, order the people our of the space, and if needed, initiate the emergency and rescue procedure.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Rescue Operations:Rescue operations in a Confined Space shall only be conducted when the proper PPE is used.Leadership shall document those individuals who are authorized to be Rescue Team Members.Equipment:Electrically powered equipment inside a Confined Space shall use a 32/50 volt or less transformer or else, use a 115/220 volt power source with a GFI or RCD that is located outside the space and that has been tested prior to use.Only lighting with a casing capable of protecting entrants from shock or bulb fragments if the bulb breaks, and that is appropriate for the electrical classification of the area shall be used in a Confined Space.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Pneumatically powered equipment shall not be powered using inert gas sources.With the exception of breathing air cylinders, pressurized gas cylinders shall not be located inside a Confined Space.Welding & cutting torches and other devices connected to pressurized gas cylinders shall be removed from Confined Spaces immediately after use. All hoses and connections shall be tested prior to use.,DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Confined Space Entry Operating Procedure:Must be a written document.When a line or equipment opening is used to prepare the CSE, then the procedure must document the line & equipment opening requirements.Must document the PPE and respiratory protective equipment requirements for entry.Must document the specific ventilation requirements.Must document the specific hazard monitoring requirements.Must provide an evaluation of any thermal stress potential and document the relief plan to address thermal stress.Must document the emergency & rescue procedures. (Includes a review of the emergency & rescue procedure with Rescue Team Members prior to entry.),DOW RESTRICTEDDOW RESTRICTED,Confined Space Entry Requirements Summary,Leadership needs to review facility and post signs on any spaces that are not easily recognizable as Confined Spaces saying that a CSE Permit is required for entry.,DOW RESTRICTEDDOW RESTRICTED,Confined Space EntryRoles & Responsibilities,Facility / Work Group LeadershipDocument CSE Permit issuers.Document CSE Permit approvers.Document list of routine, repetitive CSEs.Document list of Rescue Team Members.Label Confined Spaces that are not easily recognizable as Confined Spaces.,Personnel Issuing Safe Work & CSE Permits.Issue the permits and e
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