Month: April 2019

Hot Work – Activities that involve flame, sparks, or heat generation, which could act as a source of ignition. Hot Work includes

1. Gas and electric welding
2. Torch cutting
3. Operations using fire, or producing flame or spark

4. Powder activated tools
5. Use of electrical tools and equipment
6. Operation of internal combustion engines (gasoline, LPG or diesel) in rated area’s

Authorized Person – Trained, experienced employee who has been given the authority to issue permits to work by the Site Manager.

Acceptor – Person who accepts the permit and is in charge of the permitted work to be done.

Permit to work – Documentation that safety, health and environmental precautions have been considered and addressed prior to maintenance or non-routine tasks. The permit indicates that the person in charge of the facility, department or equipment has been informed of the work to be done.

Confined space – Any vessel or space large enough for entry that is not intended for continuous occupancy; where there exists limited means of egress and/or the potential for life threatening conditions (e.g. hazardous fumes or oxygen deficiency).

Work Area – Immediate vicinity (11 meters or 35 feet) of the place where Hot Work is performed

Area Supervisor – Person with operational control over a department or site.

The Plant Manager is responsible for ensuring that the site complies with this guidance, and audits against it, as part of their basic site SHE improvement plan.

The Plant Superintendent ensures that –

• A Line Break procedure is maintained consistent with this guidance.
• Individuals involved with the system have received adequate training
• Individuals authorized to issue and accept permits have been appointed

The Permit Issuer ensures that-

• The persons doing the permitted work understand the hazards and have adequately addressed them.
• Those signing off on the permit are aware of the meaning of their signature.
• The procedure has been followed in its entirety.
• The work location has been personally inspected by the Issuer.

Authorized Person’s Duties:

1. Know space hazards, including information on the mode of exposure, signs or symptoms, and consequences of the exposure
2. Use appropriate PPE properly

A. Protective Lockout/Tagout Materials and Hardware

• Lockout devices must be substantial enough to prevent removal without the use of excessive force or unusual techniques, such as bolt cutters or other metal cutting tools.
• Tagout devices must be substantial enough to prevent inadvertent or accidental removal. Tagout devices must be non-reuseable, attachable by hand, self-locking, and non-releaseable with a minimum unlocking strength of no less than 50 pounds. An example would be the one piece, workplace environment compatible, nylon cable tie.
• All lockout and tagout devices must indicate, singularly, the identity of the person applying the device. Each person must have their own tags and locks, if possible. Three approaches are:
  • Identifying or stamping locks with an identifying number
  • Providing numbered locks to be assigned to individuals at the start of the job. A record of the lock assignment must be maintained during the work period.
  • Providing color code locks and tags for different departments in addition to a personal ID number.
• Tags shall be constructed and printed to withstand the site environment and weather conditions to insure they will not deteriorate or the message becomes illegible during the work period.
• All tagout devices must warn against hazardous conditions that will occur if the equipment is energized. Wording is to include: “Do Not Start, Do Not Open, Do Not Close, Do Not Operate” and the why, e.g. working on pump, blower removed from the line, etc.

B. Standardized Lockout and Tagout Devices

Within the facility, all lockout and tagout devices must be standardized: color, shape (or size), printing, and format.

C. Limitation of Tags

They are warning devices only, not a physical restraint.

If attached to an energy isolating device, they must not be removed, bypassed or damaged.
They must be legible and understandable by all personnel.
The attachment must be able to withstand the work environment and not be easily detached.
They should not to be taken as a false sense of security, all affected people must be made aware of the reason for the tag – i.e. “work in progress”.

 

The Plant manager is responsible for ensuring that the site comply with this guidance, audit  the compliance, and assure that the necessary resources necessary for compliance are in place.

The Plant Superintendent ensures that –

• Lockout/Tagout systems are in use, and their effectiveness periodically audited
• Individuals involved with the system have received adequate training.
• Ensuring permits are carried out according to the agreed upon procedures
• Only authorized individuals approve the permits-to-work.
• All affected personnel are adequately trained to identify permit required tasks and situations.

Lockout/Tagout Procedure Implemented by a Group

If more than one individual is required to lockout and/or tagout equipment, each person must place their own personal lockout/tagout device on the energy isolating device. The level of protection of the group LO/TO must be the same as applicable to the individual lockout – tagout. The responsibility for the group lockout/tagout may be given to an authorized person as long as:

Authorized person’s lockout/tagout device should be first on and last off.

Assumes primary responsibility for the entire number of people working  under the protection of the group lockout/tagout.

Establishes the exposure hazards with regard to the machine or equipment.

Assures that when additional personnel begin work, their individual  lockout/tagout device is added to the group lockout/tagout device, and they remove their device when work is complete.

When an energy isolating device cannot accept multiple locks or tags, a multiple lockout or tagout device can be used; for example, scissor type lockout clamp.

Another option for worker group lockout uses a single lock to lockout the equipment; placing that key in a lockout box which allows the use of multiple personal locks to secure it.

Removal of Lockout/Tagout Devices:

When a person who applied a lockout/tagout device is not available to remove it, the device can be removed if the following three conditions are met:

1. Verification by the appropriate supervision that the person who applied the device is not at the facility, that all intended work has been satisfactorily completed, and that the equipment is ready to return to service.
2. After all reasonable efforts have been made to contact the original person who locked/tagged the equipment or system to inform them that their lockout/tagout device is being removed, the lock may be removed. The authorized person must document the inability to contact the person and that work completion was checked.
3. Ensure that the person(s) have been informed that their lockout/tagout device(s) have been removed before resuming work.

Shift Change/Personnel Change:

At shift or personnel change, the personal lockout and/or tagout device shall be removed by the out-going person and replaced by the relieving in-coming person. This will minimize exposure to hazards of unexpected energization, start-up, or release of stored energy from the machine or equipment.

1 Preparation:

Inspect the equipment or system to locate and identify the type, magnitude, and hazards of the energy involved, and the energy control/isolating devices available.

2 Notification:

Notify all affected people that a lockout/tagout will be taking place and the reason why.

3 Shutdown/Isolation:

Shut off the switches, valves or other isolating devices so that equipment can be isolated from all potential hazardous energy sources.

4 Device Application:

Place individually assigned locks together with a tag on the energy isolating devices to ensure that a “safe” or “off” position is maintained. Keys for locks are to remain with the person performing the work. If several people are involved, each person is to have his own lock and key.

5 Release of Stored Energy:

All potential stored or residual energy must be relieved, restrained or otherwise rendered safe.

6 Verification of Isolation:

Testing and Verification is required to verify the effectiveness of each lockout/tagout device after checking that no personnel are exposed. After returning controls to the neutral or off position, the equipment is now locked out.

7 Restart After Work Completed:

Leave all lockout/tagout devices in-place until the work is completely finished. After servicing and/or maintenance has been completed and the equipment is ready to be returned to service, inspect for the following:

• All tools have been removed and guards reinstalled.
• A check of the area around the equipment or system has been made to insure no personnel will be exposed during reenergizing.
• All lockout/tagout devices have been removed and the equipment has been test operated.

8 Tagout Where Lockout IS NOT Possible:

If an energy isolating device is not capable of being locked out, tags are permitted only if the tagout program can be demonstrated to provide equivalent protection to a lockout program. The tagout procedures must follow the procedures outlined in section 4.1. Thorough documented training of all affected personnel is required.

When using the tagout procedure, additional safety measures must be considered, such as removing fuses, blocking control switches, opening extra disconnecting devices or removing valve handles. Tagout shall meet the following:

• They must clearly indicate that the operation or movement of the energy isolating device is prohibited.
• If not capable of being affixed directly to the lock device (valve, switch, etc.), locate as close as practical to the device. It must be clearly visible within proximity of the device.
• Following the application of tagout devices, all potentially hazardous stored or residual energy shall be relieved, disconnected, restrained, or otherwise rendered safe.
• Prior to starting work, the employee who will perform the work shall verify that isolation and deenergization have been accomplished.
• Attach tags to all points where energy control could be activated–such as start buttons, circuit breakers, lockout devices, valves or blanks.

9 Tagout Removal:

Before the tagout device is removed, and energy restored, the authorized person ensures:

The work area has been checked to ensure all people are safely positioned.

Affected personnel are notified the tagout device is being or has been removed and the equipment is ready to be operated.

Each tagout device is to be removed only by the employee who originally applied the device.

Authorization

Only an authorized person may issue a Hot Work permit. The person authorizing the permit must personally inspect the area for fire safety before signing.

Duration

The permit is valid only for the period specified on the permit, not to exceed one shift duration. If work is to continue during a shift change, a new permit is issued at the shift changeover. Should work be required beyond the specified duration, then a new permit is also issued.

Application

A Hot Work permit is required regardless of whether it is being performed by NSC employees, contractors, or visitors.

The permit must be completely filled out before work is approved.

Wherever possible, Hot Work will be conducted in a maintenance shop or other properly equipped location such as a contractor area where a plant risk assessment has determined that no permit is required.

Work Area Precautions

Prior to issuing a Hot Work Permit:

• General – Remove all combustible material within a radius of 35 feet (ca. 11 meters).
• Where possible, barriers are placed around the work to confine sparks and prevent exposure to welding flash during arc welding.
• Floors – Where combustible materials are present, floors must be swept and cleared for a radius of 11 meters (ca. 36 feet). Combustible floors are kept wet, covered with damp sand, or protected by fire-resistant shields. Where floors have been wet down, personnel operating welding or cutting equipment are to be protected from electric shock.
• Ducts – Ducts and conveyor systems that could carry sparks to distant combustibles are to be protected or shut down for the duration of the permit.
• Noncombustible Walls – If welding is to be done on a metal wall, partition, ceiling or roof, precautions will be taken to prevent ignition of combustibles on the other side. If the combustibles on the far side cannot be relocated, a fire watch will be posted.
• Pipes – If the Hot Work site is close enough to pipes or other metal that are in contact with combustible walls, close enough to cause ignition by conduction, no permit can be issued.
• Lines containing material that produce dangerous fumes when heated are to be cleaned prior to Hot Work starting.
• Containers, used drums and other items with cavities need to be thoroughly cleaned and disconnected from pipe work.
• All containers or other hollow spaces are to be vented.
• At heights – The area below the Hot Work site is roped off and posted if sparks can fall to the ground. Where possible, cover floor grills with a protective barrier to prevent falling debris.
• Where there is a risk of dust explosions:
• Remove dust from overhead area’s walls, equipment, and floors

Note that the radius of 35 feet (ca. 11 meters) could encompass adjacent property; these guidelines still apply in these cases.

Prohibitions Hot Work is not allowed if –

• Metal in contact with a combustible structure, or Hot Work on metal walls or partitions with a combustible covering.
• In sprinklered building where these are not working.
• In areas near the storage of large quantities of exposed, readily ignitable materials
• In the presence of explosive atmospheres (mixtures of flammable gases, vapors, liquids, or dusts with air),

Fire Watch

Most Hot Work permits will need a fire watch.

A fire watch is needed in any case if:

• An appreciable amount of combustibles are within 11 meters from the Hot Work.
• A large amount of easily ignited combustibles are present further than 11 meters from the Hot Work.
• Wall or floor openings within the 11-meter radius expose combustibles in adjacent areas. These openings include concealed spaces in walls or floors.

The assigned fire watch signs the permit form when these provisions have been met, indicating acceptance of the permit and his responsibilities. The fire watch has the authority to stop Hot Work at any time.

The fire watch will have the appropriate fire extinguisher available, and be trained in its use. He will know the site alarm procedure, in case a fire is started that he cannot put out. He will possess the skills to identify fire hazards.

The fire watch will remain on the job site for 30 minutes after completion to watch for post-ignition of combustibles. Once complete, the fire watch reports to the authorized person to sign-off on the Permit, stating that the area is safe.

Monitoring

Hot Work within rated areas, or anyplace where the presence of flammable vapors or gases is possible, requires LEL monitoring. Arrangements must first be made to prevent fires by:

• isolating and purging process equipment where necessary,
• reducing the risk of emissions from reliefs, vents, sample points or drains, control of other work in the area,
• removal of combustible material as described under Precautions.

See also Lockout/Tagout guidance.

Procedure for completing a Hot Work Permit

Both the Department Supervisor and the Hot Work supervisor must personally inspect the job before authorizing the permit.

Hot Work inside a confined space

Compliance with the Confined Space Entry procedure is a prerequisite.

• All Hot Work performed inside a confined space will be performed using a supplied air respirator
• Hot work to be performed inside a space that may contain explosive materials requires continuous gas monitoring as close as possible to the area of flame. For some materials continuous monitoring is not reliable. Laboratory analysis is then required.
• Gas cylinders and electric-welding machines will be outside the confined space. Gas powered welder swill be out of doors in a well-ventilated area.
• Ventilation for the confined space will be located to remove fumes and smoke from the Hot Work and keep the concentration of fumes in the breathing zone within safe limits.

All personnel and workers associated with lockout/tagout procedures must receive appropriate training to ensure that they know how to perform their assigned responsibilities as covered in the site specific requirements. This training must include those who normally operate the equipment, as well as those who will conduct the actual lockouts and/or tagouts.

Authorized persons must receive training prior to their initial involvement with any lockout or tagout operation to ensure that they can identify hazardous energy sources and their isolation methods and means.

Retraining will be given whenever there is a change in equipment or process that presents a new hazard or a change in the hazardous energy control procedures. Retraining at least annually must be completed even when no changes have been made. Retraining will also be given whenever the periodic audit shows problems in the procedures.

Include in the training:

• the purpose and use of the lockout/tagout procedures;
• the recognition, control, and isolation of hazardous energy sources;
• the limitations of tags; and
• the importance of respect for the lockout/tagout methods including the one key/tag per person requirement.

Documented training includes names, who conducted the training, and the dates of the training, and how the trainer verified that the material was understood.

Capable

An energy isolating device will be considered capable of being locked out if:

1. It is designed with a hasp or other attachment to which a lock can be  affixed or a locking mechanism is built into it that allows isolation of  the energy source.
2. Lockout can sometimes be achieved without the need to dismantle, or  permanently alter the energy isolating device. For example, some valves  and breakers are not designed to be locked, but they can be secured with  chains, pins, blocking braces or wedges, all of which can be locked out.

Energy Isolating Device

A mechanical device that physically prevents the transmission or release of energy. Examples include an electrically operated circuit breaker, an electrical disconnect, a process block valve, a line blank in a flange, or removal of a spool piece/pipe section, etc.

Hydraulic or Hydrostatic Pressure:

Energy potential in pipelines, such as pump pressure or hydrostatic heads on process material lines, must have blind flanges or pancakes installed and/or the lines are to be disconnected. This applies to inlet and outlet lines that are connected to blowers, pumps, etc., that are being locked out.

Multiple Energy Sources

Some types of equipment or systems will have more than one type of energy release potential. A system, such as a refrigeration system or drying system, may include a number of pieces of equipment which may be difficult to separately isolate. Great care must be taken, each and every time lockout/tagout is used, to ensure that all energy sources are effectively deenergized or isolated.

Authorized [1] Personnel (Employees)

Responsibilities include:

1. All personnel working on machinery are required to lockout and tag the energy isolation device(s) with their own lock and tag.
2. Report any LOTO&T deficiencies to your supervisor or the Lockout Coordinator.
3. Contact your supervisor if your lock or key is lost.
4. Advise your supervisor if they need to lock out equipment due to shift change.

Engineering/Maintenance Manager (Lockout Coordinator)

Responsibilities include:

• The maintenance and updating of the Lock Out Tag Out Program document;
• Oversee development of existing equipment and task specific energy control procedures
• Oversight of Energy Control Procedure inspections;

Project/Process Engineers

Responsibilities include:

1. The development for energy control procedures for any equipment newly installed or modified within their project scope.

Production Manager

Responsibilities include:

1. Authorize lock removals for absent employees using the Lock Removal Procedure for Absent Employees (Attachment 2).
2. Maintain a list of “authorized” personnel along with their unique key number.

Supervisors

Responsibilities include:

1. Identify potential energy sources on new or modified equipment using the Energy Source Evaluation Form (Attachment 3).
2. Assist the Facility Lockout Committee with completion and review of Energy Control Procedures.
3. Advise the LOTO Coordinator when there are changes to equipment/machines that may affect ECP’s and when there are any deficiencies to the program.
4. Train departmental employees in the respective energy control procedures.
5. Maintain departmental energy control procedures and ensure ECP’s are posted on the respective equipment.
6. Initiate lockout procedures upon request.
7. Overall responsibility for group lockout.

Health & Safety Manager

Responsibilities include:

1. Coordinate changes in program reported through LOTO Coordinator
2. Serve in advisory capacity when requested by LOTO Coordinator or site personnel

[1] An authorized  person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment.