The purpose of INEOS Group Guidance Notes (IGGNs) is to collate best practice (internal and external) on specific topics that have caused Safety, Health or Environmental concerns within INEOS.
INEOS 集团指导说明（IGGN）的目的是汇总在 INEOS 内部和外部针对特定主题的最佳实践，这些主题曾引发安全、健康或环境方面的关注。
INEOS 集团指导说明（IGGN）的目的是汇总在 INEOS 内部和外部针对特定主题的最佳实践，这些主题曾引发安全、健康或环境方面的关注。
Implementation of the IGGN is designed to remove/manage the risk. All elements of the IGGN must be formally reviewed by each business, site
IGGN 的实施旨在消除或管理风险。INEOS 内的每个业务、工厂
IGGN 的实施旨在消除或管理风险。INEOS 内的每个业务、工厂
Full implementation will achieve the desired best practice and INEOS expects businesses, sites & facilities to continually evolve their procedures, practices and training towards this.
全面实施将实现预期的最佳实践，INEOS 期望各业务、工厂和设施不断完善其程序、实践和培训，以朝此目标持续发展。
全面实施将实现预期的最佳实践，INEOS 期望各业务、工厂和设施不断完善其程序、实践和培训，以朝此目标持续发展。
However to ensure the minimum step change improvement to remove/manage the original risk, the IGGN lists the specific mandatory items that must be incorporated into all businesses, sites & facilities.
然而，为确保实现消除或管理原始风险的最低改进要求，IGGN 列出了所有业务、工厂和设施必须纳入的具体强制性项目。
然而，为确保实现消除或管理原始风险的最低改进要求，IGGN 列出了所有业务、工厂和设施必须纳入的具体强制性项目。
These are listed below. Any gaps from these must be closed by incorporating the requirements into the business, site & facility procedures, practices and training.
如下所示。任何与这些要求不符的地方，必须通过将相关要求纳入企业、场地及设施的程序、规范和培训中予以补充完善。
如下所示。任何与这些要求不符的地方，必须通过将相关要求纳入企业、场地及设施的程序、规范和培训中予以补充完善。
| Permit to Work / LOTO - Mandatory Items 作业许可证 / 上锁挂牌 - 强制性项目 |
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| IGGN Section IGGN 章节 | Description 描述 | Site Confirm 现场确认 |
| 2.8 | A joint job-site inspection by the permit issuer (or delegate as per 2.13) and permit acceptor must be completed before issuing a permit to work. (see section 2.8 for exceptions) 在签发作业许可证之前，许可证签发人（或根据 2.13 条的指定代表）和许可证接受人必须共同进行现场检查。（例外情况见 2.8 节） |
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| 2.10 & 3.2 | Before issuing a Permit to Work, the Lock-Out/Tag-Out (LOTO) must be applied (see section 2.10) and kept secure throughout work scope (see section 3.2). 在签发作业许可证之前，必须实施上锁/挂牌（LOTO）（见 2.10 节），并在整个作业范围内保持安全（见 3.2 节）。 |
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| 2.11-13 & 4.1-2 & 4.12 | The permit issuer, qualified permit issuer designate and permit acceptor must be proven competent to issue or receive permits respectively. They both must be thoroughly familiar with the job to be permitted. Training must be documented with periodic refresher training. 许可证签发人、合格的许可证签发指定人和许可证接受人必须分别具备签发或接收许可证的能力。他们都必须对即将批准的作业非常熟悉。培训必须有记录，并定期进行复训。 |
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| 2.16 | Procedure deviation to the minimum isolation standard described in the IGGN (see section 3.0) can only be done when it is supported by a specified risk assessment and authorised by a higher level of management. 只有在有明确的风险评估支持并经更高层级管理授权的情况下，才可以偏离 IGGN 中所述的最低隔离标准（见第 3.0 节）。 |
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| 3.1 | The PTW issuing group is responsible for ensuring the equipment to be worked on has been properly isolated from all sources of potential energy before issuing permits on that equipment. Energy isolation carried out by PTW 签发小组有责任确保在签发该设备的作业许可证前，所需作业的设备已与所有潜在能量源正确隔离。由 |
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| Permit to Work / LOTO - Mandatory Items 作业许可证 / LOTO - 强制性项目 |
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| IGGN Section IGGN 章节 | Description 描述 | Site Confirm 现场确认 |
| 3.4 | Each site must follow a risk assessment process to determine the minimum level of equipment isolation required for safe separation from each process/utility. This risk assessment will determine whether positive isolation is required (i.e. blind or air gap), proved isolation is required (i.e. with a single valve and bleed or double block and bleed) or a non-proved isolation is allowed (i.e. block valve with no bleed). For hazardous systems, where a leak past a single block and bleed configuration could lead to severe consequences (e.g. toxic service, highly corrosive service, highly flammable service, high pressure and/or high temperature service) a double block and bleed must be the default requirement. In rare and exceptional circumstances a lower level of isolation may be considered on these severe consequence systems, but this must be approved by the Site Manager/Director following appropriate risk assessment to ensure no exposure to personnel. (examples of some site risk assessment tables are attached in Appendix 8.6) 每个现场必须遵循风险评估流程，以确定实现与各工艺/公用工程安全隔离所需的最低设备隔离级别。该风险评估将确定是否需要正隔离（即加盲板或空气间隙）、验证隔离（即单阀加放空或双阀加放空），或允许非验证隔离（即无放空的截止阀）。对于危险系统，如果单阀加放空配置发生泄漏可能导致严重后果（如有毒介质、高腐蚀性介质、高易燃介质、高压和/或高温介质），则必须默认采用双阀加放空。在极少数特殊情况下，对于这些严重后果系统，可以考虑采用较低级别的隔离，但必须经过适当的风险评估，并由现场经理/总监批准，以确保人员不受暴露。（部分现场风险评估表的示例见附录 8.6） |
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| 3.5 | For positive isolation using blinds, the blinding process must have a system to track the location and status of blinds installed in the plant. Special precautions should be taken when removing slip blinds or end blinds in hazardous service. In this case, vented slip blinds or bleeder end blinds may be a solution to prove zero energy between the closed valve and blind before removal. 对于使用盲板进行正隔离，必须有一套系统来跟踪安装在装置内的盲板的位置和状态。在拆除用于危险介质的插板盲板或端盲板时，应采取特殊预防措施。在这种情况下，带排气孔的插板盲板或带放空口的端盲板可以作为一种解决方案，以在拆除前证明关闭阀门与盲板之间为零能量。 |
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| 3.8 | For any intrusive work, all break points (e.g. process flange connections, equipment to be opened, new tie-in points, cutting lines, etc...) must be jointly reviewed and verified in the field by the permit issuer and acceptor during the job-site inspection prior to issuing the PTW. Controls need to be established to ensure that the wrong break point is not opened (i.e. live process). 对于任何侵入性作业，所有断开点（如工艺法兰连接、需开启的设备、新的连接点、切割线等）必须在签发作业许可证前，由许可证签发人和接受人在现场联合检查并确认。必须建立控制措施，确保不会打开错误的断开点（即带压工艺）。 |
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| 3.9 | All requirements listed in section 3.9 that cover cutting into a pipe or cable for any purpose. 第 3.9 节中列出的所有要求，涵盖了出于任何目的对管道或电缆进行切割的情况。 |
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| 3.10 | Before intrusive work commences and the pipe or equipment is opened, zero pressure must be positively confirmed by at least one method before the break. 在开始侵入性作业并打开管道或设备之前，必须至少通过一种方法在断开前明确确认为零压力。 |
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| 3.11 | Before work commences where electrical isolation is required, zero electrical energy must be confirmed. 在需要进行电气隔离的作业开始前，必须确认电气能量为零。 |
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| 3.12 | Troubleshooting a live electrical system must be a last resort. (see section 3.12 for allowable circumstances) 对带电电气系统进行故障排查必须作为最后手段。（允许的情况见第 3.12 节） |
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| 3.13 | Requirements detailed in section 3.13 to address nitrogen risks associated with equipment isolation. 第 3.13 节详细说明了针对设备隔离相关氮气风险的要求。 |
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| Permit to Work / LOTO - Mandatory Items 作业许可证 / LOTO - 强制项目 |
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| IGGN Section IGGN 部分 | Description 描述 | Site Confirm 现场确认 |
| 4.3 | Each site must have a risk ranking process established to determine whether a specific job is low risk, medium risk or high risk. 每个现场必须建立风险分级流程，以确定某项具体作业属于低风险、中风险还是高风险。 |
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| 4.5 | The complete scope of work must be described on the permit in enough detail so that both the permit issuer and permit acceptor are clear on what equipment is impacted and what the potential hazards are. 工作许可上必须详细描述完整的工作范围，以便工作许可签发人和接受人都能清楚了解受影响的设备以及潜在的危害。 |
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| 4.6 | If a JSA or JSP was required for the job, it must be reviewed by ALL workers signed onto the PTW before starting work in the field. A documented immediate pre-task hazard assessment (PTHA) must be completed by all workers in the field before they start work on the permitted job e.g 'Take 2'. 如果该作业需要 JSA 或 JSP，则所有在 PTW 上签字的工作人员在现场开始作业前，必须对其进行审核。所有现场工作人员在开始执行许可作业前，必须完成一份有记录的即时作业前危害评估（PTHA），例如“Take 2”。 |
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| 4.7 | When any scope changes from the permitted work, the people in the field must stop work and report the change to the work permit issuer. This will result in an updated or new permit. 当许可作业的工作范围发生任何变更时，现场人员必须停止作业并向工作许可签发人报告变更情况。这将导致工作许可被更新或重新签发。 |
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| 4.8 | Hand-off/closure of the PTW must be carried out at the end of the job or shift end. The hand-off must include a discussion, site visit if necessary and sign-off on the permit by both issuer and acceptor. PTW 的交接/关闭必须在作业结束或班次结束时进行。交接必须包括讨论、必要时的现场检查，并由签发人和接受人在工作许可上签字确认。 |
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| 4.9 | A process must be in place where Operations will perform a detailed risk assessment for any operation tasks which are not covered by an SOP or JSP and are non-routine and high risk. 必须建立一个流程，由运行部门对所有未被 SOP 或 JSP 覆盖、且属于非常规和高风险的操作任务进行详细的风险评估。 |
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| 4.13 | Each site must define their document retention policy for work permits. 每个现场必须制定其作业许可证文件的保存政策。 |
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| 3.14 & 4.14 | Management must establish an auditing program for the permit to work and LOTO systems. 管理层必须为作业许可证和 LOTO 系统建立审核程序。 |
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| 5.0 | All elements in section 5.0 Additional Requirements for (Hot Work) Permits are considered mandatory items. 第 5.0 节“（动火）许可证附加要求”中的所有要素均为强制性项目。 |
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| 6.0 | All elements in section 6.0 Confined Space Entry are considered mandatory items. 第 6.0 节受限空间进入中的所有要素均为强制性项目。 |
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| 7.0 | All elements in section 7.0 Working at Heights are considered mandatory items. 第 7.0 节高处作业中的所有要素均为强制性项目。 |
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Key Changes in V27.1 (version changes highlighted in yellow)
V27.1 版的主要变更（版本变更以黄色高亮显示）
§ 2.1 - Entry into a confined space added to definitions section.
§ 2.1 - 进入受限空间已添加到定义部分。
§ 2.1 - 进入受限空间已添加到定义部分。
1.0 General 1.0 总则
1.1 Improper risk assessment and risk management are key contributors to industry incidents. Permit to Work (PTW) and Lock-out Tag-out (LOTO) or Equipment Isolation (EI) systems are key components in the risk assessment and management process. It is a focus of behavioural safety principle #8 within the INEOS 20 Safety Principles.
1.1 不当的风险评估和风险管理是行业事故的主要原因。作业许可证（PTW）和上锁挂牌（LOTO）或设备隔离（EI）系统是风险评估和管理流程中的关键组成部分。这也是 INEOS 20 项安全原则中行为安全原则第 8 条的重点内容。
1.1 不当的风险评估和风险管理是行业事故的主要原因。作业许可证（PTW）和上锁挂牌（LOTO）或设备隔离（EI）系统是风险评估和管理流程中的关键组成部分。这也是 INEOS 20 项安全原则中行为安全原则第 8 条的重点内容。
This guidance document has been created to provide some of the requirements necessary to help ensure that risk is properly assessed and managed in the field. The document is not intended to be all inclusive, but focus on the key areas of PTW and EI systems, where failing to follow these requirements may lead to an incident.
本指导文件旨在提供一些必要的要求，以帮助确保在现场对风险进行适当的评估和管理。该文件并非面面俱到，而是聚焦于 PTW 和 EI 系统的关键领域，在这些领域未能遵守相关要求可能导致事故发生。
1.2 The terms ‘should’, ‘may’ and ‘must’ are used throughout this IGGN:
1.2 本 IGGN 中使用了“应”、“可以”和“必须”等术语：
本指导文件旨在提供一些必要的要求，以帮助确保在现场对风险进行适当的评估和管理。该文件并非面面俱到，而是聚焦于 PTW 和 EI 系统的关键领域，在这些领域未能遵守相关要求可能导致事故发生。
1.2 The terms ‘should’, ‘may’ and ‘must’ are used throughout this IGGN:
1.2 本 IGGN 中使用了“应”、“可以”和“必须”等术语：
- should - used where the statement is recommended as an industry best practice
应 - 用于表示该陈述被推荐为行业最佳实践 - may - used where equal alternatives are acceptable or options exist
可 - 用于表示有同等可接受的替代方案或存在选项 - must - used where the statement is a mandatory INEOS practice
必须 - 用于表示该陈述为 INEOS 强制性做法
2.0 Definitions 2.0 定义
2.1 Confined Space Entry - Confined space - is a Restricted space which has the potential to expose personnel to hazards that require controls to prevent injury or death. These hazards may include: engulfment/entrapment, hazardous atmospheres, or other serious safety or health hazards. Entry into the confined space means the action by which a person passes through an opening into a permit-required confined space. Entry is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the confined space.
2.1 受限空间进入 - 受限空间是指可能使人员暴露于需要采取控制措施以防止伤害或死亡的危险的受限制空间。这些危险可能包括：被吞没/困住、有害气体环境，或其他严重的安全或健康危害。进入受限空间是指人员通过开口进入需要作业许可证的受限空间的行为。当进入者身体的任何部分突破受限空间开口的平面时，即视为已进入。
2.2 Confined Space Entry - Restricted space - is an enclosed or partially enclosed space, not designed or intended for continuous human occupancy that has a limited or restricted means of entry or exit.
2.2 受限空间进入 - 受限制空间是指封闭或部分封闭的空间，不为人员持续停留而设计或建造，且进出方式有限或受限。
2.3 Equipment Isolation - The separation of plant and equipment from every source of energy (pressure, electrical and mechanical, radioactive, etc…) in such a way that the separation is secure. The Isolation Envelope is that part of the system within the isolation points forming the boundary within which intrusive work can be performed.
2.3 设备隔离 - 指将装置和设备与所有能源来源（压力、电力和机械、放射性等）进行分离，并确保分离安全可靠。隔离包络区是指在隔离点之间形成的系统部分，其边界内可以进行干预性作业。
2.4 Hazardous Substance - A substance which is able to cause harm or damage if loss of containment occurs. In some cases, for example water, the pressure and temperature of the water will determine if it is hazardous.
2.4 危险物质——如果发生失控泄漏，能够造成伤害或损害的物质。在某些情况下，例如水，其压力和温度将决定其是否为危险物质。
2.5 Immediate Pre-Task Hazard Assessment (PTHA) - Also known as a Take-2, Take-5, 60 second check, 2 Minute Stand Back or Last Minute Observation at some INEOS sites. It is a documented assessment of the Job to be completed in the field by all workers identified on the permit to work. This hazard assessment should be completed at the jobsite immediately prior to the start of work after the permit to work has been issued. The
2.5 作业前即时危险评估（PTHA）——在某些 INEOS 现场也称为 Take-2、Take-5、60 秒检查、2 分钟后退或最后一分钟观察。这是对所有在作业许可证上标明的工人在现场即将完成的作业进行的书面评估。该危险评估应在作业许可证签发后、作业开始前立即在作业现场完成。
intention is to review the hazards one last time at the job site before starting work. (see appendix 8.4 for example of a PTHA card)
目的是在作业开始前，最后一次在作业现场检查危险因素。（参见附录 8.4，PTHA 卡片示例）
2.6 Intrusive Work - Work which requires the opening (breaking) of process equipment, process vessels, or the line break of process piping. Hazardous energy/substance may be released if not isolated and decontaminated properly.
2.6 侵入性作业——需要打开（破开）工艺设备、工艺容器或对工艺管道进行断线的作业。如果未正确隔离和去污，可能会释放危险能量/物质。
2.7 Job Safety Analysis (JSA) - Also known as Job Hazard Analysis (JHA), a JSA is a systematic analysis of the steps involved in a job. It involves breaking the job down into smaller defined steps, identifying the hazard(s) involved with each step and developing the controls to address the hazards and reduce the risk to an acceptable level. Representatives from each trade group involved in the task along with operations, as a minimum, should participate. (see appendix 8.2 for examples of JSAs)
2.7 作业安全分析（JSA）- 也称为作业危害分析（JHA），JSA 是对作业步骤进行系统性分析的方法。它包括将作业分解为更小的明确步骤，识别每个步骤中涉及的危害，并制定控制措施以应对这些危害，将风险降低到可接受水平。参与该任务的各工种代表以及运行人员至少应共同参与。（有关 JSA 的示例，请参见附录 8.2）
2.8 Job-Site Inspection - Also known as Workplace Inspection. The Permit Issuer, or a qualified designate from the issuing group, and the Permit Acceptor will visit the job-site together and perform the following tasks:
2.8 作业现场检查 - 也称为工作场所检查。作业许可证签发人或签发组中具备资格的指定人员，以及作业许可证接受人将共同前往作业现场，并执行以下任务：
2.1 受限空间进入 - 受限空间是指可能使人员暴露于需要采取控制措施以防止伤害或死亡的危险的受限制空间。这些危险可能包括：被吞没/困住、有害气体环境，或其他严重的安全或健康危害。进入受限空间是指人员通过开口进入需要作业许可证的受限空间的行为。当进入者身体的任何部分突破受限空间开口的平面时，即视为已进入。
2.2 Confined Space Entry - Restricted space - is an enclosed or partially enclosed space, not designed or intended for continuous human occupancy that has a limited or restricted means of entry or exit.
2.2 受限空间进入 - 受限制空间是指封闭或部分封闭的空间，不为人员持续停留而设计或建造，且进出方式有限或受限。
2.3 Equipment Isolation - The separation of plant and equipment from every source of energy (pressure, electrical and mechanical, radioactive, etc…) in such a way that the separation is secure. The Isolation Envelope is that part of the system within the isolation points forming the boundary within which intrusive work can be performed.
2.3 设备隔离 - 指将装置和设备与所有能源来源（压力、电力和机械、放射性等）进行分离，并确保分离安全可靠。隔离包络区是指在隔离点之间形成的系统部分，其边界内可以进行干预性作业。
2.4 Hazardous Substance - A substance which is able to cause harm or damage if loss of containment occurs. In some cases, for example water, the pressure and temperature of the water will determine if it is hazardous.
2.4 危险物质——如果发生失控泄漏，能够造成伤害或损害的物质。在某些情况下，例如水，其压力和温度将决定其是否为危险物质。
2.5 Immediate Pre-Task Hazard Assessment (PTHA) - Also known as a Take-2, Take-5, 60 second check, 2 Minute Stand Back or Last Minute Observation at some INEOS sites. It is a documented assessment of the Job to be completed in the field by all workers identified on the permit to work. This hazard assessment should be completed at the jobsite immediately prior to the start of work after the permit to work has been issued. The
2.5 作业前即时危险评估（PTHA）——在某些 INEOS 现场也称为 Take-2、Take-5、60 秒检查、2 分钟后退或最后一分钟观察。这是对所有在作业许可证上标明的工人在现场即将完成的作业进行的书面评估。该危险评估应在作业许可证签发后、作业开始前立即在作业现场完成。
intention is to review the hazards one last time at the job site before starting work. (see appendix 8.4 for example of a PTHA card)
目的是在作业开始前，最后一次在作业现场检查危险因素。（参见附录 8.4，PTHA 卡片示例）
2.6 Intrusive Work - Work which requires the opening (breaking) of process equipment, process vessels, or the line break of process piping. Hazardous energy/substance may be released if not isolated and decontaminated properly.
2.6 侵入性作业——需要打开（破开）工艺设备、工艺容器或对工艺管道进行断线的作业。如果未正确隔离和去污，可能会释放危险能量/物质。
2.7 Job Safety Analysis (JSA) - Also known as Job Hazard Analysis (JHA), a JSA is a systematic analysis of the steps involved in a job. It involves breaking the job down into smaller defined steps, identifying the hazard(s) involved with each step and developing the controls to address the hazards and reduce the risk to an acceptable level. Representatives from each trade group involved in the task along with operations, as a minimum, should participate. (see appendix 8.2 for examples of JSAs)
2.7 作业安全分析（JSA）- 也称为作业危害分析（JHA），JSA 是对作业步骤进行系统性分析的方法。它包括将作业分解为更小的明确步骤，识别每个步骤中涉及的危害，并制定控制措施以应对这些危害，将风险降低到可接受水平。参与该任务的各工种代表以及运行人员至少应共同参与。（有关 JSA 的示例，请参见附录 8.2）
2.8 Job-Site Inspection - Also known as Workplace Inspection. The Permit Issuer, or a qualified designate from the issuing group, and the Permit Acceptor will visit the job-site together and perform the following tasks:
2.8 作业现场检查 - 也称为工作场所检查。作业许可证签发人或签发组中具备资格的指定人员，以及作业许可证接受人将共同前往作业现场，并执行以下任务：
- Verify the scope of work and the exact piece of equipment to be worked on.
核实作业范围及需作业的具体设备。 - Establish the conditions for a safe work place (i.e. Required PPE).
建立安全作业环境的条件（如所需的个人防护装备）。 - Review of other activities and hazards in the same area which may impact the permitted work.
审查同一区域内可能影响许可作业的其他活动和危害。 - Jointly verify in the field, zero energy of any process, electrical or mechanical isolations.
在现场共同确认所有工艺、电气或机械隔离的零能量状态。 - Jointly verify in the field, the location of any break points.
在现场共同确认所有断点的位置。
A joint job-site inspection must be completed before issuing a permit to work unless:
除非有特殊情况，否则在签发作业许可证前必须完成联合作业现场检查。
除非有特殊情况，否则在签发作业许可证前必须完成联合作业现场检查。
- It is a continuation of a job with the same permit acceptor and there have been no changes in job scope. The area conditions have been recently verified by the permit issuer.
这是同一作业许可接受人继续进行的作业，且作业范围没有发生变化。作业区域的条件已由作业许可签发人近期核查。 - Equipment preparation/isolation is not required for the work. The permit issuer has recently visited the area of work to assess condition and another visit by the permit issuer would not add value. (e.g. fugitive emissions checks, vibration routes, lighting repairs, etc…)
该作业不需要设备准备/隔离。作业许可签发人已于近期到作业区域评估现场情况，再次到场不会带来额外价值。（例如：无组织排放检查、振动巡检、照明维修等……）
In all cases where a joint job-site inspection is not completed, the reason why not must be documented.
在所有未完成联合现场检查的情况下，必须记录未进行的原因。
2.9 Job Specific Procedure (JSP) - Typically used by maintenance for completion of a routine task. Similar to the SOP, they are recommended to be developed using JSA methodology.
2.9 作业专用程序（JSP）——通常由维修部门用于完成例行任务。与 SOP 类似，建议采用 JSA 方法进行编制。
2.10 Lock-out Tag-out (LOTO) - A process to ensure the isolation envelope is kept secure from every source of energy (pressure, electrical, mechanical, radioactive, etc…) so that intrusive work can be completed safely. It involves the placement of a lock/tag or tag only on an energy-isolating device in accordance with an established procedure, indicating that the energy-isolating device is not to be operated until removal of the lock/tag or tag only in
2.10 上锁挂牌（LOTO）——一种确保隔离边界从所有能源来源（压力、电力、机械、放射性等）保持安全的流程，以便可以安全地完成介入性作业。该流程包括根据既定程序，在能源隔离装置上放置锁/挂牌或仅挂牌，表明在未按照既定程序移除锁/挂牌或仅挂牌前，不得操作该能源隔离装置。
accordance with established procedures. The LOTO must be applied before the PTW is issued.
LOTO 必须在 PTW（作业许可证）签发前实施。
2.11 Permit Acceptor - Also known as Permit Receiver. It is the person who is responsible for accepting the permit to work. This person must be proven competent to accept a permit and the training documentation must be maintained. The permit acceptor is responsible for ensuring all workers signing onto the permit meet all the permit requirements. In order to accept the permit, the permit acceptor must be thoroughly familiar with the job to be completed (i.e. understand all details of the work scope to be completed under the PTW). They will also carry out the job-site inspection (workplace visit) accompanied by the permit issuer prior to accepting the PTW as per the Job-site Inspection definition above.
2.11 作业许可证接受人 - 也称为许可证接收人。指负责接受作业许可证的人员。该人员必须经过能力认证，能够接受许可证，并且相关培训文件必须予以保存。许可证接受人负责确保所有在许可证上签字的工作人员均符合所有许可证要求。为接受许可证，许可证接受人必须对将要完成的作业非常熟悉（即了解在作业许可证（PTW）下需完成的所有工作范围细节）。在接受作业许可证前，许可证接受人还需与许可证签发人一同进行作业现场检查（工作场所巡视），具体要求见上文作业现场检查的定义。
2.12 Permit Issuer - The person, who is responsible for issuing the permit to work. This person must be proven competent to issue a permit and the training documentation must be maintained. The permit issuer must be thoroughly familiar with the job to be completed and have carried out a job-site inspection (workplace visit) accompanied by the permit acceptor prior to accepting the PTW. (see Job-site Inspection definition)
2.12 作业许可证签发人 - 指负责签发作业许可证的人员。该人员必须经过能力认证，能够签发许可证，并且相关培训文件必须予以保存。许可证签发人必须对将要完成的作业非常熟悉，并且在接受作业许可证（PTW）前，需与许可证接受人一同进行作业现场检查（工作场所巡视）。详见作业现场检查的定义。
2.13 Permit Issuer Qualified Designate - The Permit Issuer may designate a person from the permit issuing group to perform the Job-Site Inspection with the permit acceptor. This designate must be been trained to issue permits and have a full understanding of the scope of work. The practice is typically used during peak work times such as a maintenance Turnaround.
2.14 Permit to Work (PTW) - Also known as a Safe Work Permit (SWP). A permit to work is an agreement between the issuer and the acceptor that authorizes specific work, at a specific work location, for a specific time period. Permits are used for controlling and coordinating work to establish and maintain safe working conditions. They ensure that all foreseeable hazards have been considered and that the appropriate precautions are defined and carried out in the correct sequence. They should be issued for work which may adversely affect the safety of personnel, the plant or the environment.
2.15 Piping and Instrument Diagram (P&ID) - A schematic drawing defining the extent of equipment, piping and piping components and instrumentation. Preferred document to be used in a controlled fashion to identify the isolation points used to ensure a safe process isolation envelope.
2.16 Procedure Deviation - Also known as variation from procedure. A safety procedure deviation in context to this IGGN is a situation where circumstances require the use of isolation to a lower standard than the baseline isolation standard. Use of the safety deviation is acceptable only when it is supported by a situation-specific risk assessment. Safety deviations must be appropriately authorised by a higher level of management and fully recorded.
2.17 Procedure in Hand - The requirement to have the SOP or JSP in hand when working on the task in the field. This means a working copy of the procedure is being marked up in the
field with each step being signed off. Requirements to have a procedure in hand should be influenced by the following factors:
在所有未完成联合现场检查的情况下，必须记录未进行的原因。
2.9 Job Specific Procedure (JSP) - Typically used by maintenance for completion of a routine task. Similar to the SOP, they are recommended to be developed using JSA methodology.
2.9 作业专用程序（JSP）——通常由维修部门用于完成例行任务。与 SOP 类似，建议采用 JSA 方法进行编制。
2.10 Lock-out Tag-out (LOTO) - A process to ensure the isolation envelope is kept secure from every source of energy (pressure, electrical, mechanical, radioactive, etc…) so that intrusive work can be completed safely. It involves the placement of a lock/tag or tag only on an energy-isolating device in accordance with an established procedure, indicating that the energy-isolating device is not to be operated until removal of the lock/tag or tag only in
2.10 上锁挂牌（LOTO）——一种确保隔离边界从所有能源来源（压力、电力、机械、放射性等）保持安全的流程，以便可以安全地完成介入性作业。该流程包括根据既定程序，在能源隔离装置上放置锁/挂牌或仅挂牌，表明在未按照既定程序移除锁/挂牌或仅挂牌前，不得操作该能源隔离装置。
accordance with established procedures. The LOTO must be applied before the PTW is issued.
LOTO 必须在 PTW（作业许可证）签发前实施。
2.11 Permit Acceptor - Also known as Permit Receiver. It is the person who is responsible for accepting the permit to work. This person must be proven competent to accept a permit and the training documentation must be maintained. The permit acceptor is responsible for ensuring all workers signing onto the permit meet all the permit requirements. In order to accept the permit, the permit acceptor must be thoroughly familiar with the job to be completed (i.e. understand all details of the work scope to be completed under the PTW). They will also carry out the job-site inspection (workplace visit) accompanied by the permit issuer prior to accepting the PTW as per the Job-site Inspection definition above.
2.11 作业许可证接受人 - 也称为许可证接收人。指负责接受作业许可证的人员。该人员必须经过能力认证，能够接受许可证，并且相关培训文件必须予以保存。许可证接受人负责确保所有在许可证上签字的工作人员均符合所有许可证要求。为接受许可证，许可证接受人必须对将要完成的作业非常熟悉（即了解在作业许可证（PTW）下需完成的所有工作范围细节）。在接受作业许可证前，许可证接受人还需与许可证签发人一同进行作业现场检查（工作场所巡视），具体要求见上文作业现场检查的定义。
2.12 Permit Issuer - The person, who is responsible for issuing the permit to work. This person must be proven competent to issue a permit and the training documentation must be maintained. The permit issuer must be thoroughly familiar with the job to be completed and have carried out a job-site inspection (workplace visit) accompanied by the permit acceptor prior to accepting the PTW. (see Job-site Inspection definition)
2.12 作业许可证签发人 - 指负责签发作业许可证的人员。该人员必须经过能力认证，能够签发许可证，并且相关培训文件必须予以保存。许可证签发人必须对将要完成的作业非常熟悉，并且在接受作业许可证（PTW）前，需与许可证接受人一同进行作业现场检查（工作场所巡视）。详见作业现场检查的定义。
2.13 Permit Issuer Qualified Designate - The Permit Issuer may designate a person from the permit issuing group to perform the Job-Site Inspection with the permit acceptor. This designate must be been trained to issue permits and have a full understanding of the scope of work. The practice is typically used during peak work times such as a maintenance Turnaround.
2.14 Permit to Work (PTW) - Also known as a Safe Work Permit (SWP). A permit to work is an agreement between the issuer and the acceptor that authorizes specific work, at a specific work location, for a specific time period. Permits are used for controlling and coordinating work to establish and maintain safe working conditions. They ensure that all foreseeable hazards have been considered and that the appropriate precautions are defined and carried out in the correct sequence. They should be issued for work which may adversely affect the safety of personnel, the plant or the environment.
2.15 Piping and Instrument Diagram (P&ID) - A schematic drawing defining the extent of equipment, piping and piping components and instrumentation. Preferred document to be used in a controlled fashion to identify the isolation points used to ensure a safe process isolation envelope.
2.16 Procedure Deviation - Also known as variation from procedure. A safety procedure deviation in context to this IGGN is a situation where circumstances require the use of isolation to a lower standard than the baseline isolation standard. Use of the safety deviation is acceptable only when it is supported by a situation-specific risk assessment. Safety deviations must be appropriately authorised by a higher level of management and fully recorded.
2.17 Procedure in Hand - The requirement to have the SOP or JSP in hand when working on the task in the field. This means a working copy of the procedure is being marked up in the
field with each step being signed off. Requirements to have a procedure in hand should be influenced by the following factors:
- The task is high risk and non-routine
该任务属于高风险且非常规任务 - The task is very complex
该任务非常复杂 - The task carries over a shift change requiring handover mid-procedure
该任务需要跨班次交接，在操作过程中需进行交接 - The specific SOP or JSP requires sign-off on each step (e.g. for environmental compliance, etc… ).
特定的 SOP 或 JSP 要求每一步都需签字确认（例如，为了环境合规等）
2.18 Routine Work - A task performed on a frequent or regular basis (i.e. daily, weekly, monthly). In order to be considered “routine”, the task must be conducted on a frequent or regular basis by the trained worker(s) performing the work. This type of work would normally be controlled by a Standard Operating Procedure (SOP).
2.19 Standard Operating Procedure (SOP) - Typically used by Operators, SOPs are detailed written instructions to achieve uniformity in completion of a specific task. They are to be followed in carrying out a given operation or in a given situation. These procedures are recommended to be formatted in a task/hazard/controls format (i.e. JSA methodology). Documented training and validation for each SOP must be available.
3.0 Requirements for Equipment Isolation
3.1 The PTW issuing group is responsible for ensuring the equipment to be worked on has been properly isolated from all sources of potential energy (electrical, process, mechanical, radioactive, etc…) before issuing any permits to work on that equipment. Special care must be taken by PTW issuing group to fully understand the isolation envelope when completed by a
3.1 PTW 签发小组负责确保在签发任何作业许可证之前，需作业的设备已与所有潜在能量源（如电力、工艺、机械、放射性等）正确隔离。PTW 签发小组必须特别注意，在由
3.2 The PTW acceptor must ensure the isolation envelope is kept secure while their work is being completed. Best practice would have the permit acceptor apply a “group” lock or tag and an “individual” lock or tag which ensures the isolation envelope is kept secure. The group lock/tag becomes critical when work extends over more than one shift, where the permit accepting group needs to assure the equipment cannot be put back into service while their work is not complete. The group lock/tag is left on the LOTO for duration of the group’s work scope, while individual locks/tags are only on the LOTO when individuals within the group are working on it. This prevents, through potential miscommunication, the permit issuing group from removing the LOTO to re-commission the system when it is not ready.
3.3 For equipment isolation an effective system is required to ensure you can indicate and effectively secure the position of manually operated valves. This may be achieved through a (LOTO) lock/tag or tag only system. The key is establishment of a site process which is diligently followed.
3.4 Each site must follow a risk assessment process to determine the minimum level of equipment isolation required for safe separation from each process/utility. This risk
assessment will determine whether positive isolation is required (i.e. blind or air gap), proved isolation is required (i.e. with a single valve and bleed or double block and bleed) or a non-proved isolation is allowed (i.e. block valve with no bleed). For hazardous systems, where a leak past a single block and bleed configuration could lead to severe consequences (e.g. toxic service, highly corrosive service, highly flammable service, high pressure and/or high temperature service) a double block and bleed must be the default requirement. In rare and exceptional circumstances, a lower level of isolation may be considered on these severe consequence systems, but this must be approved by the Site Manager/Director following appropriate risk assessment to ensure no exposure to personnel. (examples of some site risk assessment tables are attached in Appendix 8.6)
3.5 For positive isolation using blinds, the blinding process must have a system to track the location and status of blinds installed in the plant. Special precautions should be taken when removing slip blinds or end blinds in hazardous service. In this case, vented slip blinds or bleeder end blinds may be a solution to prove zero energy between the closed valve and blind before removal.
3.6 A marked-up diagram of the system to be isolated should accompany each LOTO prepared. The isolation points need to be clearly identified on the diagram and cross referenced to the LOTO list. For process isolation the best practice would be to use current site P&ID’s, but if not, diagrams may need to be created. For isolation of electrical systems only, electrical line diagrams may be appropriate. The site MOC process should include control of these P&ID’s or diagrams used to ensure they remain current. A step in the LOTO process should include verification that the diagram being used matches what is in the field.
3.7 Once the LOTO is applied in the field, there should be an independent verification process where a second set of eyes ensures that the LOTO has been applied as planned. This involves ensuring that hazardous energy has been controlled, equipment isolation devices are in the proper position, lockout devices are properly installed, tags and locks are in the proper locations and that zero energy has been verified.
3.8 For any intrusive work, all break points (e.g. process flange connections, equipment to be opened, new tie-in points, cutting lines, etc…) must be jointly reviewed and verified in the field by the permit issuer and acceptor during the job-site inspection prior to issuing the PTW. Controls need to be established to ensure that the wrong break point is not opened (i.e. live process).
3.1 PTW 签发小组负责确保在签发任何作业许可证之前，需作业的设备已与所有潜在能量源（如电力、工艺、机械、放射性等）正确隔离。PTW 签发小组必须特别注意，在由
3.2 The PTW acceptor must ensure the isolation envelope is kept secure while their work is being completed. Best practice would have the permit acceptor apply a “group” lock or tag and an “individual” lock or tag which ensures the isolation envelope is kept secure. The group lock/tag becomes critical when work extends over more than one shift, where the permit accepting group needs to assure the equipment cannot be put back into service while their work is not complete. The group lock/tag is left on the LOTO for duration of the group’s work scope, while individual locks/tags are only on the LOTO when individuals within the group are working on it. This prevents, through potential miscommunication, the permit issuing group from removing the LOTO to re-commission the system when it is not ready.
3.3 For equipment isolation an effective system is required to ensure you can indicate and effectively secure the position of manually operated valves. This may be achieved through a (LOTO) lock/tag or tag only system. The key is establishment of a site process which is diligently followed.
3.4 Each site must follow a risk assessment process to determine the minimum level of equipment isolation required for safe separation from each process/utility. This risk
assessment will determine whether positive isolation is required (i.e. blind or air gap), proved isolation is required (i.e. with a single valve and bleed or double block and bleed) or a non-proved isolation is allowed (i.e. block valve with no bleed). For hazardous systems, where a leak past a single block and bleed configuration could lead to severe consequences (e.g. toxic service, highly corrosive service, highly flammable service, high pressure and/or high temperature service) a double block and bleed must be the default requirement. In rare and exceptional circumstances, a lower level of isolation may be considered on these severe consequence systems, but this must be approved by the Site Manager/Director following appropriate risk assessment to ensure no exposure to personnel. (examples of some site risk assessment tables are attached in Appendix 8.6)
3.5 For positive isolation using blinds, the blinding process must have a system to track the location and status of blinds installed in the plant. Special precautions should be taken when removing slip blinds or end blinds in hazardous service. In this case, vented slip blinds or bleeder end blinds may be a solution to prove zero energy between the closed valve and blind before removal.
3.6 A marked-up diagram of the system to be isolated should accompany each LOTO prepared. The isolation points need to be clearly identified on the diagram and cross referenced to the LOTO list. For process isolation the best practice would be to use current site P&ID’s, but if not, diagrams may need to be created. For isolation of electrical systems only, electrical line diagrams may be appropriate. The site MOC process should include control of these P&ID’s or diagrams used to ensure they remain current. A step in the LOTO process should include verification that the diagram being used matches what is in the field.
3.7 Once the LOTO is applied in the field, there should be an independent verification process where a second set of eyes ensures that the LOTO has been applied as planned. This involves ensuring that hazardous energy has been controlled, equipment isolation devices are in the proper position, lockout devices are properly installed, tags and locks are in the proper locations and that zero energy has been verified.
3.8 For any intrusive work, all break points (e.g. process flange connections, equipment to be opened, new tie-in points, cutting lines, etc…) must be jointly reviewed and verified in the field by the permit issuer and acceptor during the job-site inspection prior to issuing the PTW. Controls need to be established to ensure that the wrong break point is not opened (i.e. live process).
Examples of how this can be achieved:
- by having the permit issuer or acceptor present when the break is completed.
- identifying the break point with a tag for someone else who may work on the permit but is not as intimate with the job scope as the issuer or acceptor.
- some other controls that achieve the same intention
3.9 Because of the increased risk involved when cutting into a line for any purpose (e.g. demolition, tie-ins, etc…), there are additional controls beyond what is listed in 3.8 above:
Pipe Cutting:
- All pipework to be cut must have every cut location marked directly on the cut surface (i.e. bare pipework with insulation removed) using a tag which cannot be moved accidentally (i.e. sticker or label). Remember the simple rule: No Tag no Cut!
- The tag must contain a unique identifier that is tied back to the work order and PTW.
- The tag must have three names with signatures on it before the cut work starts:
- Person from the equipment owner team (typically INEOS Plant Operator) or permit issuer.
- Person who owns the scope of work (typically Project/Maintenance Supervisor or Planner) or permit acceptor.
- Person performing the cut must be physically shown all cut locations by the permit issuer or acceptor and then sign the tag immediately before starting the cut work. They must confirm that the right tag number and other two signatures are present.
Cable Cutting:
- Prior to the cutting of an electrical cable of any voltage, the cable must be positively identified and isolated from all energy sources. This entails ensuring that the cable is physically disconnected from all sources of electrical energy (i.e. removed from the distribution center / MCC) and subsequently verifying its positive identification (e.g. signal injection, cable ring, etc.) and confirming its state of being electrically inert or non-energized.
- The positive identification of the cable must be verified by a suitably trained and competent individual at each designated cut location.
- Each cable must be tagged in accordance with the pipe cutting requirements above unless it has a previously identified cut point or disconnected end in which case a) a cable ring or similar device can be moved from the open end to the new cut point or b) the cable can be pulled back/withdrawn to give positive identification and a new cut point. When working in a bunch of cables each cable must be managed one at a time.
- A risk assessment must be generated by the site for every cable or group of cables intended for cutting. This document should encompass a record of the steps undertaken and the endorsement from individuals involved in the positive identification and cutting of the cables. It is imperative that this document be attached or incorporated into the Permit to Work to ensure proper documentation and traceability.
- If a cable cannot be positively identified, then permission to cut will only be granted in extremely rare circumstances. Only actually done a few times in the history of INEOS, permission will only be considered if all other options have been exhausted and even then only following a thorough multi expert risk assessment (internal and external experts), peer review with another business and then final sign-off by the business Operations Director. The risk assessment must ensure that all personnel are excluded from the area during any activity that may breech the cable and/or release energy and must also consider the potential for a plant shutdown and arc flash with the mitigations and contingencies in place to minimize the risk. If approved, the first cut must be
completed by a remote method for personal safety (e.g. cartridge operated spike, hydraulic or electric cutting tool).
3.10 Before intrusive work commences and the pipe or equipment is opened, zero pressure must be positively confirmed by at least one method before the break. This will typically be at a drain, pressure gauge or pressure transmitter within the isolation envelope of the system to be broken. If zero energy cannot be confirmed by at least one method, the site requires an escalation process where further risk analysis and approval is completed before proceeding with the break (e.g. Management approval). Caution needs be taken to ensure the proving drain is clear of material and that the gauge used is accurate for showing zero energy.
3.11 Before work commences where electrical isolation is required, zero electrical energy must be confirmed. Together, the permit issuer and permit acceptor are required to attempt and then document that an equipment start was tried and was unsuccessful before the PTW is issued. Caution needs to be taken to ensure a potential interlock is not holding out the piece of electrical equipment, giving a false positive result. There must be documented equipment isolation training and competency checks developed into a site’s management system. This should also include periodic refresher training and retraining when the site equipment isolation process is changed.
3.12 Sometimes it may be necessary to troubleshoot a live electrical system as a last resort. This activity must only be done under the following circumstances: - The troubleshooting can only be performed with the system live as a last resort.
- The person conducting the troubleshooting on the electrical system must be trained, qualified and authorized to work on the potential voltage exposure in the live electrical system.
- Site procedures for work on live electrical systems must be established for the site and followed with the necessary PPE to prevent injury.
3.13 Equipment at risk of a nitrogen rich atmosphere requires special control measures to reduce the hazard. Inhaling a nitrogen rich atmosphere reduces the oxygen level to the blood making it immediately life threatening. Nitrogen rich atmospheres have no smell to warn of the risk so be mindful, whether or not a confined space entry is required, as nitrogen can flow out of equipment when opened up and reduce the oxygen level close to the created opening.
There are specific requirements to address the hazard when preparing for isolation, line breaking and opening. The PTW process must address the following:
- Identification of all potential sources of nitrogen that could enter the equipment and the controls in place to prevent this from happening.
- An assessment of the atmosphere immediately local to the equipment opened for work and where people may be present or working in the vicinity.
- Potential for any structures constructed in support of the work activity which have the potential to trap gas or impact natural ventilation (e.g. weather protective sheeting or “tents”).
- Suitable signage and access prevention to be placed at entrance of open equipment to warn of an oxygen deficient atmosphere.
- If equipment has been purged with nitrogen to create an inert atmosphere then additional measures may be necessary even when entry is not required:
- The use of a portable oxygen detector to warn if the oxygen concentration in the vicinity of the opening drops below
. - The use of breathing air to provide protection.
3.14 Management must establish an auditing program for the equipment isolation system.
4.0 Requirements for Permit to Work
4.1 A PTW must only be issued by a person who has been trained to issue permits. This person must be completely familiar with the work or situation covered by the permit and who has responsibility for operational status in that work area. This becomes particularly important when more than one permit is being issued in an area with potential conflicts between permits. The permit should be job specific. The PTW must be posted in a highly visible place at the PTW issue point. A Job-Site inspection, as defined in Job-Site Inspection in the definitions section, must take place prior to issuing the PTW.
4.2 A PTW must only be accepted by a person who has been trained to accept permits. The person accepting the permit must completely understand the work situation, the potential hazards, and the precautions required before accepting the permit. They are responsible to ensure all requirements agreed with the permit issuer are met. This includes ensuring all workers who are signed onto the permit meet all the permit and risk assessment requirements. A Job-Site inspection, as defined in Job-Site Inspection in the definitions section, must take place prior to accepting the PTW.
4.3 Each site must have a risk ranking process established to determine whether a specific job is low risk, medium risk or high risk. (An example tool for this risk ranking is attached in Appendix 8.1). For work which is not covered by an SOP or JSP and is non-routine and high risk, a JSA should be required before the permit to work is issued. This JSA would then be reviewed as part of the permit issuing process.
4.4 No one should sign a safe work permit unless they are completely satisfied that the work can be done safely.
4.5 The complete scope of work must be described on the permit in enough detail so that both the permit issuer and permit acceptor are clear on what equipment is impacted and what the potential hazards are. Reference to any other associated permits or documents need to be noted on the PTW (e.g. LOTOs, blind plans, photo’s, etc…).
4.6 A documented immediate pre-task hazard assessment (PTHA) must be completed by all workers in the field before they start work on the permitted job. If a JSA or JSP was required for the job, it must be reviewed by all workers signed on the PTW before starting work in the field.
4.7 During the work period, after the permit has been issued, the permit issuer should periodically spot check the work in the field to ensure the scope of work has not deviated from the permit issued. When any scope changes from the permitted work, the people in the field must stop work and report the change to the work permit issuer. A new or updated permit may be required.
4.8 Proper hand-off/closure of the PTW is essential at the end of the job scope or shift end so that the permit issuing group understands the current status of the job and if the job is complete, that the equipment is safe to return to service. The hand-off must include a discussion, site visit if necessary and sign-off on the permit by both the issuer and acceptor. If the original permit issuer is not available for sign-off, someone who is trained to issue permits and is responsible for the area can sign for the issuer.
4.9 A process must be in place where Operations will perform a detailed risk assessment for any operation tasks which are not covered by an SOP or JSP and are non-routine and high risk. This may involve issuing of a PTW or other site established process which ensures the risk is thoroughly assessed and understood before the operations task starts. (see example operator risk assessment in appendix 8.3)
4.10 The scope of this document is not intended to cover emergency plant situations where immediate action may be required. The site’s specific emergency response protocols will take precedence in such a situation.
4.11 There are times when a procedure in-hand is necessary to ensure the task is done safely. Sites need to establish their criteria when this is required (see “procedure in hand” in definitions section).
4.12 There must be documented permit issuing and accepting training and competency checks developed into a site’s management system. This should also include periodic refresher training or retraining when the permit process is changed.
4.13 Each site must define their document retention policy for Work Permits.
4.14 The auditing protocol should cover all aspects of the PTW from: building, issuing, use, suspension, closure and also the site required retention of permits.
4.2 A PTW must only be accepted by a person who has been trained to accept permits. The person accepting the permit must completely understand the work situation, the potential hazards, and the precautions required before accepting the permit. They are responsible to ensure all requirements agreed with the permit issuer are met. This includes ensuring all workers who are signed onto the permit meet all the permit and risk assessment requirements. A Job-Site inspection, as defined in Job-Site Inspection in the definitions section, must take place prior to accepting the PTW.
4.3 Each site must have a risk ranking process established to determine whether a specific job is low risk, medium risk or high risk. (An example tool for this risk ranking is attached in Appendix 8.1). For work which is not covered by an SOP or JSP and is non-routine and high risk, a JSA should be required before the permit to work is issued. This JSA would then be reviewed as part of the permit issuing process.
4.4 No one should sign a safe work permit unless they are completely satisfied that the work can be done safely.
4.5 The complete scope of work must be described on the permit in enough detail so that both the permit issuer and permit acceptor are clear on what equipment is impacted and what the potential hazards are. Reference to any other associated permits or documents need to be noted on the PTW (e.g. LOTOs, blind plans, photo’s, etc…).
4.6 A documented immediate pre-task hazard assessment (PTHA) must be completed by all workers in the field before they start work on the permitted job. If a JSA or JSP was required for the job, it must be reviewed by all workers signed on the PTW before starting work in the field.
4.7 During the work period, after the permit has been issued, the permit issuer should periodically spot check the work in the field to ensure the scope of work has not deviated from the permit issued. When any scope changes from the permitted work, the people in the field must stop work and report the change to the work permit issuer. A new or updated permit may be required.
4.8 Proper hand-off/closure of the PTW is essential at the end of the job scope or shift end so that the permit issuing group understands the current status of the job and if the job is complete, that the equipment is safe to return to service. The hand-off must include a discussion, site visit if necessary and sign-off on the permit by both the issuer and acceptor. If the original permit issuer is not available for sign-off, someone who is trained to issue permits and is responsible for the area can sign for the issuer.
4.9 A process must be in place where Operations will perform a detailed risk assessment for any operation tasks which are not covered by an SOP or JSP and are non-routine and high risk. This may involve issuing of a PTW or other site established process which ensures the risk is thoroughly assessed and understood before the operations task starts. (see example operator risk assessment in appendix 8.3)
4.10 The scope of this document is not intended to cover emergency plant situations where immediate action may be required. The site’s specific emergency response protocols will take precedence in such a situation.
4.11 There are times when a procedure in-hand is necessary to ensure the task is done safely. Sites need to establish their criteria when this is required (see “procedure in hand” in definitions section).
4.12 There must be documented permit issuing and accepting training and competency checks developed into a site’s management system. This should also include periodic refresher training or retraining when the permit process is changed.
4.13 Each site must define their document retention policy for Work Permits.
4.14 The auditing protocol should cover all aspects of the PTW from: building, issuing, use, suspension, closure and also the site required retention of permits.
5.0 Additional Requirements for (Hot Work) Permits
5.1 Goal should be to eliminate or minimize hot work whenever possible. All alternatives to hot work must be considered before proceeding (e.g. cold cutting vs. grinding or open flame cutting, taking equipment to be worked on outside of the asset/plant environment).
5.2 A thorough risk assessment is required for hot work, utilising scope-of-work experts and fire response experts as necessary.
5.3 All personnel issuing hot work permits require specific documented training over and above regular safe work permit training. The training to include detailed understanding of the elements listed in this section 5.0.
5.4 The person in charge of operating the affected process equipment in the area where the hot work is to take place must be involved in the authorization of the hot work permit. It is imperative that the impact of any process upset on the hot work being performed be fully understood so that timely actions can be taken.
5.5 Additional level of approval over a safe work permit must be applied for high risk hot work involving open flame or sparks on process piping or equipment within an asset/plant environment (i.e. Asset/Plant Manager responsible for the area in which the work is being carried out).
5.6 A change in operating conditions or environment may have major consequences due to the ignition source potential. All personnel involved in preparing, authorising and conducting the work must have this explained to them prior to work commencing. The requirement to stop work and re-assess if a change has occurred is paramount.
5.7 Hot work on process piping or equipment must be thoroughly assessed by a person who has an intimate understanding of the equipment to be purged. It is important to understand the potential for any trapped residual flammable hydrocarbons.
5.8 When purging a system which previously contained a flammable substance, extra care is required to ensure all flammables have been removed. A heated purge (e.g. steam, hot nitrogen, etc…) may be necessary to ensure heavy hydrocarbons are purged properly from the system.
5.9 Gas testing must be completed both externally and internally for work on process piping or equipment. Internal testing to even include process piping or equipment which has been removed from the asset/plant environment and is being worked on in a maintenance shop or laydown area. Requirement is to achieve
5.10 Ensure that gas testing equipment used is suitable for use after purging (i.e. that the measurement will not be adversely affected by the presence of inert gas or depleted levels of oxygen). Also be aware liquids or steam drawn into the gas testing equipment will give false reading and potentially damage the testing equipment.
5.11 Ensure users of gas testing equipment are thoroughly trained to understand the limits and correct application of the testing equipment. (e.g. limitations of combustion style gas monitors in low O2 environment).
5.12 The person testing a confined space needs to ensure the sample tested is representative of the atmosphere where the hot work will be completed. The equipment used to perform the
test should be bump tested (zero checked) against a known standard at least once per day before use.
5.13 Continuous atmospheric monitoring must be utilised for hot work in potentially flammable areas.
5.14 Area drains/sewers must be considered a source of flammables. The risk assessment must specifically address this issue which may result in drains being covered, plugged, isolated or even maybe left open with water running depending on design of drain/sewers. The result must be that flammables cannot travel down the drain to the vicinity of the hot work area. The drain/sewer must be gas tested to ensure no flammables are present.
5.15 Combustible materials in the hot work area, which cannot be removed, must be effectively shielded/covered from hot work using flame retardant materials.
5.16 A designated trained fire watch person must be appointed and shall have no other duties that would distract from the primary safety surveillance. They should remain during breaks and after work is completed for at least 30 minutes to ensure there is no risk of fire.
5.2 A thorough risk assessment is required for hot work, utilising scope-of-work experts and fire response experts as necessary.
5.3 All personnel issuing hot work permits require specific documented training over and above regular safe work permit training. The training to include detailed understanding of the elements listed in this section 5.0.
5.4 The person in charge of operating the affected process equipment in the area where the hot work is to take place must be involved in the authorization of the hot work permit. It is imperative that the impact of any process upset on the hot work being performed be fully understood so that timely actions can be taken.
5.5 Additional level of approval over a safe work permit must be applied for high risk hot work involving open flame or sparks on process piping or equipment within an asset/plant environment (i.e. Asset/Plant Manager responsible for the area in which the work is being carried out).
5.6 A change in operating conditions or environment may have major consequences due to the ignition source potential. All personnel involved in preparing, authorising and conducting the work must have this explained to them prior to work commencing. The requirement to stop work and re-assess if a change has occurred is paramount.
5.7 Hot work on process piping or equipment must be thoroughly assessed by a person who has an intimate understanding of the equipment to be purged. It is important to understand the potential for any trapped residual flammable hydrocarbons.
5.8 When purging a system which previously contained a flammable substance, extra care is required to ensure all flammables have been removed. A heated purge (e.g. steam, hot nitrogen, etc…) may be necessary to ensure heavy hydrocarbons are purged properly from the system.
5.9 Gas testing must be completed both externally and internally for work on process piping or equipment. Internal testing to even include process piping or equipment which has been removed from the asset/plant environment and is being worked on in a maintenance shop or laydown area. Requirement is to achieve
5.10 Ensure that gas testing equipment used is suitable for use after purging (i.e. that the measurement will not be adversely affected by the presence of inert gas or depleted levels of oxygen). Also be aware liquids or steam drawn into the gas testing equipment will give false reading and potentially damage the testing equipment.
5.11 Ensure users of gas testing equipment are thoroughly trained to understand the limits and correct application of the testing equipment. (e.g. limitations of combustion style gas monitors in low O2 environment).
5.12 The person testing a confined space needs to ensure the sample tested is representative of the atmosphere where the hot work will be completed. The equipment used to perform the
test should be bump tested (zero checked) against a known standard at least once per day before use.
5.13 Continuous atmospheric monitoring must be utilised for hot work in potentially flammable areas.
5.14 Area drains/sewers must be considered a source of flammables. The risk assessment must specifically address this issue which may result in drains being covered, plugged, isolated or even maybe left open with water running depending on design of drain/sewers. The result must be that flammables cannot travel down the drain to the vicinity of the hot work area. The drain/sewer must be gas tested to ensure no flammables are present.
5.15 Combustible materials in the hot work area, which cannot be removed, must be effectively shielded/covered from hot work using flame retardant materials.
5.16 A designated trained fire watch person must be appointed and shall have no other duties that would distract from the primary safety surveillance. They should remain during breaks and after work is completed for at least 30 minutes to ensure there is no risk of fire.
6.0 Confined Space Entry
6.1 A person shall not carry out work in confined spaces if it is reasonably practical that it could be avoided. Initial assessment of a confined space entry requires a formal review to see if the work can be done another way to avoid entry into the confined space.
6.2 Entry into any confined space for the purpose of carrying out work which presents Immediate Danger to Life or Health (IDLH) is prohibited for INEOS employees. If entry is absolutely required, INEOS will hire a third party specializing in this activity. A higher level of management approval and risk assessment is required. Where entry is required for the purpose of carrying out rescue under IDHL conditions, this is permitted provided the conditions are appropriately risk assessed and are noted as part of an approved rescue plan. Rescue shall only be carried out by those who are trained and competent in this task.
6.2 Entry into any confined space for the purpose of carrying out work which presents Immediate Danger to Life or Health (IDLH) is prohibited for INEOS employees. If entry is absolutely required, INEOS will hire a third party specializing in this activity. A higher level of management approval and risk assessment is required. Where entry is required for the purpose of carrying out rescue under IDHL conditions, this is permitted provided the conditions are appropriately risk assessed and are noted as part of an approved rescue plan. Rescue shall only be carried out by those who are trained and competent in this task.
For more information on IDLH entry please refer to IGGN-29 - Diving Operations.
6.3 Entry into a confined space is considered when any part of a person’s body breaks the plane of the opening into the confined space.
6.4 Each Site must have all their identified confined spaces listed within their confined space procedure. This procedure must form a key part of confined space training.
6.5 If a confined space exists that can be readily entered (e.g. vessel skirting), permanent physical barriers (typically metal cross or mesh) and signs must be posted at the point(s) of entry warning of the confined space:
(e.g. “Danger - Confined Space, Permit required for Entry, do not enter”).
6.6 Each Site needs to have a process in place to identify and assess any new potential confined spaces (e.g. welding tents, poly-wrapped scaffold structures, spaces where instrument air has the potential to be substituted with nitrogen, removed equipment in workshop where entry is possible or nitrogen is used for purging, etc…)
6.3 Entry into a confined space is considered when any part of a person’s body breaks the plane of the opening into the confined space.
6.4 Each Site must have all their identified confined spaces listed within their confined space procedure. This procedure must form a key part of confined space training.
6.5 If a confined space exists that can be readily entered (e.g. vessel skirting), permanent physical barriers (typically metal cross or mesh) and signs must be posted at the point(s) of entry warning of the confined space:
(e.g. “Danger - Confined Space, Permit required for Entry, do not enter”).
6.6 Each Site needs to have a process in place to identify and assess any new potential confined spaces (e.g. welding tents, poly-wrapped scaffold structures, spaces where instrument air has the potential to be substituted with nitrogen, removed equipment in workshop where entry is possible or nitrogen is used for purging, etc…)
Leaks of nitrogen in analyser buildings have led to fatalities in industry. If possible, removing the walls of the analyser building is the best solution. If not, low oxygen detectors in the building must be tied to both audible and visual alarms at the analyzer building and control room, to warn of an IDLH atmosphere.
6.7 For all persons involved with a confined space entry (i.e. Entrants, Attendants, Entry Supervisors and Rescue Personnel) the site must have documented training for each role associated with the confined space entry.
6.8 If precautionary respiratory protection is required for the confined space entry or a potential rescue, all persons who may need to wear respiratory protection must have documented training on use of respiratory equipment. As per section 6.2, if the atmosphere cannot support life, entry cannot be made.
6.9 Because of the immediate life threatening nature of nitrogen exposure, there are specific requirements to address nitrogen hazards for every confined space entry. The confined space risk assessment completed must address the following:
6.7 For all persons involved with a confined space entry (i.e. Entrants, Attendants, Entry Supervisors and Rescue Personnel) the site must have documented training for each role associated with the confined space entry.
6.8 If precautionary respiratory protection is required for the confined space entry or a potential rescue, all persons who may need to wear respiratory protection must have documented training on use of respiratory equipment. As per section 6.2, if the atmosphere cannot support life, entry cannot be made.
6.9 Because of the immediate life threatening nature of nitrogen exposure, there are specific requirements to address nitrogen hazards for every confined space entry. The confined space risk assessment completed must address the following:
- Identification of all potential sources of nitrogen that could enter the confined space and the controls in place to prevent this from happening. This may include locking out nitrogen utility sources within a reasonable temporary hose reach of the confined space.
- Clear identification of the positive isolation from upstream or downstream equipment which may contain nitrogen. If the vessel/space cannot be fully isolated from adjacent vessels/spaces, the other spaces must be included in the risk assessment (see 6.30 and 6.31).
6.10 The confined space entry risk assessment to include identification and evaluation of all hazards inside and outside the permitted confined space. Additional risk arising from work being completed within the confined space must also be included in the overall risk assessment (e.g. hot work, equipment removal, etc…). The risk assessment must consider the following items at a minimum: - Oxygen deficiency caused by potential presence of nitrogen
- Oxygen deficiency or enrichment caused by internal work or material
- Creation of hazards from internal work (e.g. welding, etc…)
- Electric shock from electrical equipment
- Injury from mechanical equipment
- Contact with harmful chemicals
- Slippery surfaces, tight areas, head and elbow bangers
- Potential falling objects (e.g. residual bridged catalyst, loose trays or brick)
- Darkness, poor visibility
- Temperature extremes
- Flammable substances
- Toxic gas
- Fumes or vapour
- Radioactive sources or radioactive scale deposits
- Hazardous potential deposits or scale (e.g. Iron Sulphide, etc…)
- Sludge
- Inadvertent operation of plant
- Emissions from local drains
- Noise
- Interference of nearby external work activities etc…
6.11 Ventilation of the confined space must be considered in the risk assessment. Some confined spaces require mechanical ventilation to provide sufficient fresh air to replace the oxygen that is being used up by people working in the space, and to dilute and remove gas, fume or vapour produced by the work. This can be done by using a blower fan and trunking and/or an exhaust fan or ejector and trunking (provided that there is an adequate supply of fresh air to replace the used air). Fresh air should be drawn from a point where it is not contaminated either by used air or other pollutants. Never introduce additional oxygen into a confined space to ‘sweeten’ the air as this can lead to oxygen enrichment in the atmosphere that can render certain substances (eg grease) liable to spontaneous combustion, and will greatly increase the combustibility of other materials. Oxygen above the normal concentration in air may also have a toxic effect if inhaled.
6.12 Positive isolation between process/utilities and the confined space is a requirement for entry. The blinding, blanking or disconnecting shall be performed as close to the confined space vessel as practical. The confined space flanges can be left open provided that attached piping has been removed, misaligned, plugged or blinded to prevent product entry into the confined space. As a default, all instruments, attachments and fittings are to be removed from the vessel. Attached instrumentation (i.e. Sight glasses, level transmitters or switches) may be included as part of the isolation for confined space if the instrumentation is confirmed open to the space and the internal atmosphere of the attached instrumentation can be confirmed as purged and safe.
6.13 All hoses and temporary piping connected to the confined space must be disconnected before the confined space entry permit can be issued to avoid inadvertent connection to process or utility service. Once the vessel is approved for entry, there must be no way to inadvertently add nitrogen into the confined space.
6.14 Lighting needs to be inherently safe or protected when it is used in potentially flammable or explosive atmospheres so that it does not present a source of ignition. The confined space should be lit well enough for Entrants to work safely and exit the space quickly in an emergency.
6.15 Electrocution, flammable or explosive atmospheres and potential for static charge build-up must be considered in the risk assessment when specifying electrical equipment to be used within a confined space. Ground fault circuit interrupter (GFCI) or a residual-current device (RCD) may be required.
6.16 Compressed gas cylinders such as those containing oxygen or acetylene shall not be allowed inside a confined space. The only pressurized cylinders allowed are for SCBA, medical resuscitation equipment, fire extinguishers or handheld aerosol spray containers. Caution should be given to the use of dry powder fire extinguishers (which could impair visibility) orfire extinguishers (which could displace the oxygen content) in the confined space.
6.17 Multiple fatalities in industry have occurred when rescuers have been overcome by the same conditions that have affected the people they have tried to rescue. To prevent this, those who have been assigned a rescue role must be aware of the risks within the space and protected against the cause of the emergency. The precautions necessary to protect the rescuers must be considered during the risk assessment, and adequate provisions made when preparing suitable and sufficient emergency arrangements.
6.18 The site must develop and implement procedures for summoning rescue and emergency services, for rescuing Entrants from confined spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue.
6.19 Rescue plans specific to the confined space to be entered must be prepared in advance of the confined space entry permit being issued. Prepared by the qualified Rescue Personnel with Entry Supervisor input, the rescue plan must address the successful retrieval of Entrants under the worst case scenarios (e.g. broken back). If there is not confidence that a successful rescue can be made, then an exercise with a ‘dummy’ person must be completed successfully or the confined space entry shall not proceed.
6.20 The confined space must be kept in a tidy, organised manner such that people can move around safely and at any time a rescue team can enter unencumbered. This requirement should form part of the overall audit protocol of the site.
6.21 The Entry Supervisor is the person trained and qualified to issue confined space entry permits. They must know the potential hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of any exposure. The Entry Supervisor needs to be a competent person who is completely familiar with the facility, equipment, confined space to be entered and applicable site safe work procedures. This person signs off the confined space entry permit when the confined space is ready for entrance.
6.22 Authorized Entrants must be trained and approved to enter the confined space. Training to include understanding the hazards of the confined space, along with the signs and
symptoms of overexposure to the confined space. They must be familiar with the equipment and safety monitoring devices being used.
6.23 Authorized Attendants, also known as ‘hole watch’ or ‘entry stand-by person’, must be able to monitor situations inside and outside the confined space. The primary role of the Attendant is to monitor from outside, those inside the confined space and raise the alarm in case of emergency. Under no circumstances is an attendant permitted to leave the space until replaced by another attendant or after all Entrants have come out of the space. If supplied air is being used by the Entrants, a second Attendant is required to monitor the bottles.
The primary role of the Authorized Attendant is to raise the alarm to summon the predetermined rescue team/plan. They must not enter the confined space to attempt a spontaneous/unplanned rescue.
6.24 The authorized Attendant is to maintain a line of communication at all times with the Entrants. The Attendant is to monitor Entrant status and also to alert Entrants of the need to evacuate the space if required. Ideally visual contact is maintained, but if not possible, radio communication can be used. If contact is lost, the entry must be terminated and all personnel must exit. A backup plan to ensure that the requirement to exit can be clearly communicated at all times must be in place even if radio contact is lost (e.g. siren or foghorn).
6.25 Any conditions making it unsafe to remove an entrance (manway) cover shall be eliminated before the cover is removed.
6.26 When entrance covers are removed, the opening shall be promptly guarded by a railing, temporary cover, or other temporary barrier as necessary to prevent an accidental fall through the opening. The barrier is also required to protect each employee working in the space from foreign objects entering the space.
6.27 The initial atmospheric testing of a confined space shall be completed with a calibrated direct-reading instrument. Results of the atmospheric test shall be logged and documented on the confined space permit. Re-testing and logging of the atmospheric conditions must be completed anytime continuous occupancy of the confined space is broken (i.e. start of a shift, after coffee breaks, etc…). Any Entrant shall be provided an opportunity to observe the pre-entry testing and/or results.
6.28 Testing to include:
6.24 The authorized Attendant is to maintain a line of communication at all times with the Entrants. The Attendant is to monitor Entrant status and also to alert Entrants of the need to evacuate the space if required. Ideally visual contact is maintained, but if not possible, radio communication can be used. If contact is lost, the entry must be terminated and all personnel must exit. A backup plan to ensure that the requirement to exit can be clearly communicated at all times must be in place even if radio contact is lost (e.g. siren or foghorn).
6.25 Any conditions making it unsafe to remove an entrance (manway) cover shall be eliminated before the cover is removed.
6.26 When entrance covers are removed, the opening shall be promptly guarded by a railing, temporary cover, or other temporary barrier as necessary to prevent an accidental fall through the opening. The barrier is also required to protect each employee working in the space from foreign objects entering the space.
6.27 The initial atmospheric testing of a confined space shall be completed with a calibrated direct-reading instrument. Results of the atmospheric test shall be logged and documented on the confined space permit. Re-testing and logging of the atmospheric conditions must be completed anytime continuous occupancy of the confined space is broken (i.e. start of a shift, after coffee breaks, etc…). Any Entrant shall be provided an opportunity to observe the pre-entry testing and/or results.
6.28 Testing to include:
- oxygen concentrations to be
and - flammability of gases, vapour, mist, dust in excess of lower flammability limit
- toxic substances that exceed permissible exposure limits
- any other atmospheric concentration that is immediately dangerous to life and health
Each site to establish testing limits well below IDLH levels and in-line with local
regulatory requirements. The exact testing, retesting and monitoring requirements should be defined by the confined space Entry Supervisor. This regular monitoring of the atmosphere in a confined space may be through the use of fixed monitors used within an area to protect a number of workers or through the use of personal/portable monitors worn by individual workers.
6.29 While oxygen concentrations outside the limits listed in 6.27 are considered IDLH for purposes of this document, any oxygen readings that deviate from the standard
6.30 When initial testing for atmospheric hazards, forced air ventilation must be turned off for a defined period of time before testing to ensure a good representative sample of the prepared confined space is collected. Test first for oxygen, then for combustible gases/vapors, and then for toxic gases/vapors. Ensure requirements in section 5.10 to 5.12 are followed.
6.31 Gas testing needs to be representative of the whole confined space area where work is taking place. Take into account isolated pockets and low points where heavier gases could collect within the space when choosing the testing and ventilation methods. For gas testing, if a representative sample of the working area cannot be obtained from the entrance of the confined space, entry under breathing air may be required to complete the initial atmospheric testing. The atmosphere is to be continuously monitored as the space is scanned. Readings approaching IDLH would require immediate evacuation and further ventilation prior to retesting. No entry is allowed if the atmosphere cannot be proven to be able to support life.
6.32 Test conditions in the permit space to determine if acceptable entry conditions exist before entry is authorized to begin. If isolation of the space is infeasible because the space is large or is part of a continuous system (such as a sewer), pre-entry testing and continuous monitoring shall be performed far enough both upstream and downstream to allow for evacuation if an alarm condition occurs. Continuously monitoring must also be completed in the areas where authorized Entrants are working.
6.33 If entry is being made into a vessel or space containing sludge or any other debris, the nature of the sludge must be ascertained, tested and confirmed it contains nothing that could create an atmosphere that cannot support life. This may involve stirring up sludge and additional testing.
6.34 Continuous gas monitoring is required during a confined space entry. Every individual or work group within the confined space should have a monitor. That monitor should test for O 2 concentration, LEL of gas of concern, toxic gas of concern (e.g.
6.35 All Entrants must wear a full body harness and be attached to a safety line to facilitate rescue in an emergency, unless the risk assessment has specified an alternate equivalent level of protection to facilitate a rescue.
6.36 If confined space entrance is required for the removal of catalyst or other bulk materials from a vessel, the stability of the surface/sub-surface of the catalyst/material needs to be assessed. Unless it can be positively confirmed that cavities have not or cannot form, then fall arrest systems must be worn by all the entrants.
6.37 There needs to be a physical system for tracking all persons and items entering and leaving the confined space (e.g. sign-in board or tag board).
6.38 If forced air ventilation of a confined space is required to maintain a safe atmosphere, the ventilation system must be either alarmed or monitored at all times by the Attendant. In the case the forced ventilation system shuts down, the Attendant needs to notify the Entrants immediately to evacuate the confined space.
6.39 If a hazardous atmosphere is detected at any time during the confined space entry, all Entrants must leave the space immediately and the entry permit withdrawn. The space shall be evaluated to determine how the hazardous atmosphere developed and measures must be put in place to protect Entrants before any subsequent entry takes place. This will involve redoing the risk assessments and entry permits.
regulatory requirements. The exact testing, retesting and monitoring requirements should be defined by the confined space Entry Supervisor. This regular monitoring of the atmosphere in a confined space may be through the use of fixed monitors used within an area to protect a number of workers or through the use of personal/portable monitors worn by individual workers.
6.29 While oxygen concentrations outside the limits listed in 6.27 are considered IDLH for purposes of this document, any oxygen readings that deviate from the standard
6.30 When initial testing for atmospheric hazards, forced air ventilation must be turned off for a defined period of time before testing to ensure a good representative sample of the prepared confined space is collected. Test first for oxygen, then for combustible gases/vapors, and then for toxic gases/vapors. Ensure requirements in section 5.10 to 5.12 are followed.
6.31 Gas testing needs to be representative of the whole confined space area where work is taking place. Take into account isolated pockets and low points where heavier gases could collect within the space when choosing the testing and ventilation methods. For gas testing, if a representative sample of the working area cannot be obtained from the entrance of the confined space, entry under breathing air may be required to complete the initial atmospheric testing. The atmosphere is to be continuously monitored as the space is scanned. Readings approaching IDLH would require immediate evacuation and further ventilation prior to retesting. No entry is allowed if the atmosphere cannot be proven to be able to support life.
6.32 Test conditions in the permit space to determine if acceptable entry conditions exist before entry is authorized to begin. If isolation of the space is infeasible because the space is large or is part of a continuous system (such as a sewer), pre-entry testing and continuous monitoring shall be performed far enough both upstream and downstream to allow for evacuation if an alarm condition occurs. Continuously monitoring must also be completed in the areas where authorized Entrants are working.
6.33 If entry is being made into a vessel or space containing sludge or any other debris, the nature of the sludge must be ascertained, tested and confirmed it contains nothing that could create an atmosphere that cannot support life. This may involve stirring up sludge and additional testing.
6.34 Continuous gas monitoring is required during a confined space entry. Every individual or work group within the confined space should have a monitor. That monitor should test for O 2 concentration, LEL of gas of concern, toxic gas of concern (e.g.
6.35 All Entrants must wear a full body harness and be attached to a safety line to facilitate rescue in an emergency, unless the risk assessment has specified an alternate equivalent level of protection to facilitate a rescue.
6.36 If confined space entrance is required for the removal of catalyst or other bulk materials from a vessel, the stability of the surface/sub-surface of the catalyst/material needs to be assessed. Unless it can be positively confirmed that cavities have not or cannot form, then fall arrest systems must be worn by all the entrants.
6.37 There needs to be a physical system for tracking all persons and items entering and leaving the confined space (e.g. sign-in board or tag board).
6.38 If forced air ventilation of a confined space is required to maintain a safe atmosphere, the ventilation system must be either alarmed or monitored at all times by the Attendant. In the case the forced ventilation system shuts down, the Attendant needs to notify the Entrants immediately to evacuate the confined space.
6.39 If a hazardous atmosphere is detected at any time during the confined space entry, all Entrants must leave the space immediately and the entry permit withdrawn. The space shall be evaluated to determine how the hazardous atmosphere developed and measures must be put in place to protect Entrants before any subsequent entry takes place. This will involve redoing the risk assessments and entry permits.
7.0 Working at Heights
7.1 Working at height is considered one of the highest risk activities we do at our sites; therefore, a thorough risk assessment must be completed for all stages of the job that involve working at height. There is a hierarchy of controls that must be evaluated in the risk assessment. In order of increased risk and priority of selection, the controls include:
- Alternatives to working at height (e.g. ground operated equipment)
- Collective passive protection (i.e. platform with proper railings and toe board to prevent a fall)
- Individual active fall restraint system preventing a worker from reaching the fall hazard (e.g. harness/fixed length lanyard to an anchor)
- Finally, as a last resort individual active fall arrest system to limit the fall distance of the worker (e.g. harness/shock absorbing lanyard).
7.2 The priority of selection must consider measures that protect everyone who is at risk (i.e. collective passive protective systems such as scaffolding) before measures that only protect the individual (i.e. personnel protection measures such as a harness).
7.3 In line with the priority of selection above, always consider passive systems such as scaffolding (where the individual does not have to do anything to activate the system) before active systems such as harnesses/lanyard (where the worker has to clip on).
7.4 For the risk assessment, both height and activities play a role. For example, it may be considered safe for a worker to climb a ladder maintaining 3 points of contact, but working off that same ladder may not be seen as safe without fall protection.
7.5 The risk assessment needs to consider all stages of the job from first activities, permitted/non-permitted work, and through clean-up. Often activities like delivery or
clean-up are forgotten during the job risk assessment, which ends up in improvisation or issues during execution.
7.6 Access to roofs is only allowed when the roof, in its entirety, is load bearing with suitable edge protection. For example, if there are skylights present, they must also be load bearing. Load bearing roofs are roofs that safely support the weight of a person and any load they are carrying or using. Refer to IGGN 25 for more details.
7.7 For working at height involving vehicles, refer to IGGN 31 (drivers at height).
7.8 In addition to this IGGN, local regulatory working at height requirements must be met.
8.0 Appendix
8.1 Sample Risk Assessment Table
8.2 Sample JSA Formats
JSA_Sample_1.doc JSA_Sample_2.doc JSA_Sample_3.doc
8.3 Sample Operator Team Risk Assessment Form
\section*{Sample Operator Team Risk Assessmer}
8.4 Sample Pre-Task Hazard Assessment Card
Risk Assessment Check Sheet
8.5 Sample Permit to Work Audit Form
Permit to Work Audit Form v1.1.xlsx
8.6 Sample Isolation Tables
