CONFINED SPACE

AWARENESS

Why discuss entry ?

Entry into a confined space is a hazardous activity
in the oil and gas business. Entry permit systems
have been in place for years but fatal accidents
continue to happen. An entry permit, by itself,
does not make entry safe.

Workplace safety depends on people factors !

Briefings and discussions like this are essential:
To maintain awareness
To learn the lessons from past accidents
To add local knowledge to the Companys procedures
Safety Talk 13 / 2

A confined space
is any space with
limited access
and escape,
where flammable
or toxic vapours
could collect,
or where the
oxygen content
could be reduced

What is a confined
space ?
Some spaces are obviously confined
eg. process vessel
Others are less obvious eg. open-topped /
floating roof tank, pit, sump, excavation
> 1m. deep
Other specific locations may be
designated as confined spaces by site
management
Note that entry includes putting your head
inside an enclosed space
eg. for visual inspection
Can you add to the list ?
Safety Talk 13 / 3

Risks of entry
Failure to identify confined space
Failure to isolate the vessel
Failure to isolate internal appliances eg. mixers
Exposure to explosive, toxic or asphyxiating
atmosphere
Exposure to hazardous materials
Risks associated with work in a confined space
eg. fumes
Inability to exit quickly in emergency
Risk from activities outside the vessel
Safety Talk 13 / 4

Risk
assessment
Plan and think through the work in
advance, involving all the relevant
people including specialists
(Ops, Maintenance, HSE)
Is entry essential, or can the work
eg. inspection be done from outside ?
All practical means must be employed to
make the vessel safe from the outside
before entry is permitted
The entry permit system is then used
to control entry
Safety Talk 13 / 5

What is an entry permit ?

An entry permit is a contract between the operating
authority and the performing authority, covering:
Responsibility for all aspects of the entry
Definition of the vessel, location, and permit validity
Isolation, and preparation of vessel and workplace
(Gas) test results
Remaining hazards and precautions
including monitoring
Completion and withdrawal of permit
Distribution of permit copies ensures all
interested parties are informed

Safety Talk 8A
13 / 6

Working in a confined space

An entry permit is not a permit
to carry out work
Additional cold, hot, electrical
permits are required as
appropriate, cross referenced
to the entry permit
Each work permit must cover
the additional hazards of
working in a confined space

Safety Talk 13 / 7

Decommissioning / isolation
Shut down and removal of oil and
gas hazards by depressuring,
draining etc.
Positive isolation* by disconnection
or blanking as near to vessel as
practical
Valve(s) isolation is not adequate
Isolation of heating coils and driven
internal appliances

*If positive isolation is impractical, entry is prohibited without

special dispensation from senior management

Safety Talk 13 / 8

Preparation of worksite
Warning notices posted and vessel clearly marked for entry
Good access and escape provided
Separate access ways for services, hoses, cables etc
All means employed to make vessel safe from the outside
before entry permitted
Remove surrounding (<15m) hazards
eg. seal drains
Vessel purged and ventilated

Safety Talk 13 / 9

Gas testing
Gas testing to be carried out, by competent
person, for oxygen, flammable and
toxic gas (in that order)
Test equipment of suitable design,
regularly inspected, tested /
calibrated and maintained
Limitations of equipment and
test method recognised
High risk areas identified and checked
Tested from outside initially, and then inside
Safety Talk 13 / 10

Entry without Breathing Apparatus (BA)

Conditions required:
Gas test results:

Oxygen 20.8% (as atmospheric air)

Flammable gas less than 1% LEL

Toxic gas less than 10% OEL

(8 hours exposure)
All traces of oil, sludge, scale etc removed
Conditions not expected to change
Adequate ventilation to maintain atmosphere

If not met, further risk assessment must be done

Safety Talk 13 / 11

Entry with suitable BA

Guidelines:

Oxygen 19.5% to 23.5% volume

Flammable gas < 10% LEL

(entry), 20% LEL (exit)

Toxic gas < STEL

(15 mins exposure)
BA wearers must have been
specifically trained and accredited
Outside the above limits the
atmosphere inside the vessel must be
considered life threatening
Safety Talk 13 / 12

Life threatening atmospheres

An entry permit must not
be issued to enter a life
threatening atmosphere
Entry under inert gas
eg. catalyst removal under nitrogen:
Only specialist contractors will enter and work in inert
atmospheres, with authorisation from senior site
management
Safety Talk 13 / 13

Summary of gas test levels

Without Breathing
Apparatus (BA)
With BA subject
to risk assessment
Unsafe

OXYGEN

FLAMMABLE

TOXIC

20.8%

<1% LEL

<10% OEL

19.5 - 23.5%
10% LEL to enter
20% LEL exit
<19.5%

>20% LEL

<STEL

>STEL

or >23.5%

OEL (Occupational exposure limit for 8 hours exposure)

STEL (Short term exposure limit for 15 minutes exposure)
Safety Talk 13 / 14

Precautions against remaining hazards

Coordination and segregation of work
to prevent dangerous interactions,
particularly for complex work
Restrictions on work to be
carried out externally and
internally
Adequate internal lighting
suitable for zone 1, and
where possible < 25 volts
PPE to be worn

Safety Talk 13 / 15

Entry permit issue and distribution

Entry permit form fully completed and issued
by operating authority to performing authority
Permit distribution ensures that the required
information is formally communicated to all
interested parties
Original to the performing authority, to be
posted at the entrance to the vessel
Copies to

Control room or other operating

centre

Operations supervisor

HSE dept

Others as decided by site

management
Safety Talk 13 / 16

Entry Tags
Tags are used to:
Reinforce the entry permit
Warn that hazardous
conditions exists
see entry permit
Prohibit entry

Safety Talk 13 / 17

Commencement of entry
PERFORMING AUTHORITY
Supervisor visits worksite

OPERATING AUTHORITY
Supervisor visits worksite

Holds a toolbox talk with those

who will carry out the work

Considers factors relating

to the specific day

Additional briefing for

contractors and
subcontractors

Gives clearance signature

to enter

Explains scope,
restrictions, timescale,
precautions, first aid
and emergency
procedures

Is present when entry first

made

Safety Talk 13 / 18

Monitoring
Repeat gas tests or continuous gas monitoring
Position Vessel Entry Standbys immediately outside the
confined space at least one with SCBA if worn for entry
Control over routine access / exit should be maintained
If conditions change, in an emergency, and if the general
alarm sounds, persons must be able to exit quickly

EVERYONE has a duty of care to those inside the vessel

ANYONE can and must raise the alarm to evacuate the
vessel if they detect a hazard to the people inside
Safety Talk 13 / 19

Vessel Entry Standby duties

Remain on duty until relieved
Maintain an accurate count of all
persons in the vessel
Maintain effective contact with the
persons inside the vessel
Use a life-line where appropriate
Monitor activities to confirm that it remains
safe for people to remain inside
Order evacuation if conditions change to
endanger people inside
Summon rescue services in an emergency
Do not enter

Safety Talk 13 / 20

Emergency action and rescue

Entry must cease if the emergency siren sounds
First action is to raise the alarm and summon
the emergency services
Only specially selected, fit, trained rescuers
can attempt rescue. Untrained persons
MUST NOT ATTEMPT RESCUE

Self contained breathing apparatus

(SCBA) must be used
If work or entry is stopped for safety
reasons,it must not be restarted until
all tests and checks are repeated and
written authorisation given
Safety Talk 13 / 21

Permit validity
Validity rules will be set by site management
according to the risks involved and the
working / shift system
Entry permits should not be valid
for more than 1 work period or day
All live entry permits must be formally
handed over at working / shift changeovers,
together with a status update

Safety Talk 13 / 22

Completion of entry
Performing authority signs and returns the
original entry permit to the operating
authority
Operating authority inspects the vessel and,
if satisfied, withdraws the permit
The original permit form should be filed for
future reference
All copies should be filed or destroyed to
ensure that only valid permits are live in the
workplace
Safety Talk 13 / 23

Higher risk work

Entry which cannot be carried out in accordance with the
entry permit system:

where gas test criteria cannot be achieved

where disconnection or spading is impractical
other entry permit rules cannot be met

Involves more detailed planning

and control procedures
Requires authorisation
by a senior manager

Safety Talk 13 / 24

Wrong equipment
A contractor entered
the cage of the wrong air cooler,
through a trap door locked with a
padlock and key. Unfortunately the
padlock was in a bad condition so he
cut it off. Luckily the fan was not
started while he was inside.

Safety Talk 13 / 25

Mixed up
Electrical isolation
must be positive
lock-out / tag out
Each vessel should
have an isolation list
There is no substitute
for walking around a
vessel, physically
checking each
connection, and
verifying positive
isolation

A worker cleaning
the inside of a vessel
was killed when the
(wrong) mixer was
inadvertantly started.

Safety Talk 13 / 26

Boxed in
Workers cleaning trays
in a column were working from
the bottom to the top. Others
boxing up man ways were working
top to bottom simultaneously to save
time. Luckily frantic banging
raised the alarm, and the
cleaners were released.

Safety Talk 13 / 27

Attempted rescue
If the mate had
called for help
he may have
saved the
workers life as
well as his own

A worker collapsed
inside a vessel. His mate
attempted to rescue him, without
raising the alarm, but was also
overcome. They were both
found dead some
time later.

Safety Talk 13 / 28

Putting your head in

An operator put his head into
the tank opening of a barge to
check the oil level. He was
overcome and fell inside the
tank and was killed.

A maintenance foreman
put his head inside a manhole
on a nitrogen purged vessel to
check details of internal
fittings. He was found
collapsed
(dead) over the manhole.

Safety Talk 13 / 29

Putting your head in again

A welder was repairing
cracks in the man way of a tank
that had been nitrogen purged.
Work was not possible with the manhole
cover in place. He dropped a torch tip
into the tank, looked inside for it,
collapsed, fell in and died.

Safety Talk 13 / 30

Enhanced combustibility

A fire broke out inside a

Hortonsphere when tarpaulins
and scaffolding boards caught
fire as a result of enhanced
combustibility due to oxygen
leaking from cutting
equipment (1 man killed).

Safety Talk 13 / 31

Pride comes before a fall

Attempting to
unplug a tank pump suction, a
contractor entered the tank through a
small opening, wearing only a cannister
respirator. There was no entry permit
and he was instructed not to go in.
He would not come out even
when felt dizzy. He was killed
by benzene vapours.

Safety Talk 13 / 32

Dangerous interactions
The permit system
should tell us all the
work and entry that is
happening at any
point in time
Large / complex jobs
and or worksites have
to be broken down
into manageable
parts

A contractor was carrying

out hot work on an overheads line
resulting in an internal fire fuel was
probably gas oil distilled over during
steaming out. The fumes migrated to the
column overcoming unprotected
workers carrying out familiarisation
training (2 deaths).

When preparing for

hot work, vapour
free does not mean
gas free

Safety Talk 13 / 33

I thought (that I knew better)

An employee was cleaning
the inside of a storage tank.
Instructed to use a steam cleaner but used
solvent because he thought it would be quicker.
He was working unsupervised. He knocked
over a container of solvent and was overcome
by vapours. A second person,
who entered the tank without breathing
apparatus, was also overcome

Another (forbidden) rescue attempt

Safety Talk 13 / 34

Competency, training and awareness

Workplace safety depends on:

Awareness, communications,
training and supervision
Care and competence of those
responsible for the work

Competencies should be
Defined in terms of skills and
experience required
Training and experience given
Confirmed by formal testing and
accreditation eg. operating and
performing authorities, gas
testers, vessel guards

Workplace safety depends on PEOPLE

Safety Talk 13 / 35

Contractor
s
Contractors should receive training in the work permit
system as part of their induction
Contractors workers
may also require:
Specialist training
eg. in wearing / using
breathing apparatus
Medical examinations to
confirm physical fitness
Safety Talk 13 / 36

Summary
Entry is one of the higher risk activities carried out in our refineries
We have pointed out the risks, and the controls that are available
in the permit system
The permit system is one of the critical controls used to establish
and maintain a safe workplace
An entry permit:

is a contract between the Operator and the Performer

defines responsibilities, scope and timing of work

raises awareness and provides a useful checklist / aide

memoire
A permit alone can never make entry safe
Only the care and competence of those who operate the system
can do that

Safety Talk 13 / 37

Optional quiz
1.

Managing risk involves (4 steps)

2.

Name 4 inherent hazards of entry

3.

Is valve isolation adequate for entry ?

4.

What important roles does the (operating) supervisor play ? (4)

5.

What important roles does the (performing) supervisor play ? (4)

6.

What important roles does the standby person outside a vessel play ? (4)

7.

What should you do if you discover a hazard that compromises the

safety of entry ? (2)

8.

What should you do if you discover a person in difficulty in a confined space ?

9.

What checks would you make if asked to enter a vessel ?

10. How can we generate interest and maintain awareness of everyday safety issues ?
(any ideas would be welcome)

Safety Talk 13 / 38

APPEND IX 1

Work permit process / responsibilities 1

Before work starts
PERFORMING AUTHORITY
Receive Work Order

OPERATING AUTHORITY
Permit required (Yes, no, type)

Application for a Work Permit: Define work scope

Raise and complete the appropriate permit form(s)

Identify hazards associated with facility operations

Identification of the hazards of performing the work

Coordination with other work

Joint planning of work with the Performing Authority

Joint planning of work with the Area Authority

Decommissioning
Decisions on isolation

Safety Talk 13 / 39

APPEND IX 1

Work permit process / responsibilities 2

OPERATING AUTHORITY

PERFORMING AUTHORITY

Preparation of equipment

Carry out isolation

Preparation of worksite environment

Preparation of worksite for the work to be done

Arranging for gas testing (by accredited gas tester)

Interpretation of gas results and decision on proceeding

Specifying precautions

Review the completed permit form and authorise

Review permit (Hot, Entry and Contractors) and accept

Issue permit
Safety Talk 13 / 40

APPEND IX 1

Work permit process / responsibilities 3

OPERATING AUTHORITY

Brief operating personnel

PERFORMING AUTHORITY

Tool box talk for work team

Permit distribution

Post copy of permit at reporting point

Post original permit at worksite

Final inspection

Commencement of work

Commencement of work

Safety Talk 13 / 41

APPEND IX 1

Work permit process / responsibilities 4

OPERATING AUTHORITY

PERFORMING AUTHORITY

Commencement of work

Commencement of work

Monitoring eg. gas monitoring

Performing work

Entry Guard, Fire Watch

Complying with restrictions

Monitoring of workplace operating hazards

Implementing precautions

Emergency and Rescue

Monitoring the work related hazards

Withdraw permit

Suspension of work, uncompleted or interrupted work

Reissue permit

Restart work

Safety Talk 13 / 42

APPEND IX 1

Work permit process / responsibilities 5

OPERATING AUTHORITY

Handover at shift and personnel changes

PERFORMING AUTHORITY

Handover at shift and personnel changes

Stopping work if conditions change making work unsafe

Completion of work

Completion of work

Clear workplace of tools, equipment, materials & workers

Sign off permit

Inspection of completed work

Hand back the equipment in a safe condition

to be recommissioned

Withdrawal of Permit
Safety Talk 13 / 43