Month: April 2019

Plant Management should define the situations where the permit-to-work is to be used, including where:

• Management deems it necessary for a given task on the basis of prior risk assessment This could be because a given task is complex and any error could have significant adverse consequences.
• The work is to done by people not under the direct supervision of the person in charge of the operating unit.
• There is a mandatory requirement for special permits. These situations would also require compliance with additional precautions.
  • Entry to a confined space
  • Hot Work
  • Line breaking with hazardous substances or under pressure.(hot Tapping)
  • Work involving electrical equipment (LO/TO)
  • Entry into a Restricted Area
    • There is an impact on another group’s activities, (i.e. On-line process equipment more than one group working with the same set of Lockouts/Tagouts).

Permits-to-Work should be:

• A standardized procedure for an entire given site.
• Verification that all check listed items have been accounted for and documented.
• Acceptance by the executing authority of responsibility for conditions listed in the permit

Permit Issuer – 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).

Excavation – Any operation which disturbs ground, walls or floors, that is large enough to present a potential hazard.

Lock out/Tag out – A systematic means of positively isolating machinery or equipment from sources of stored energy and materials hazards, in such a way that only the person doing the work will control the release of energy or material hazard. This is a tool, rather than a separate permit procedure. Also known as isolation of plant and equipment from energy and hazardous materials.

Hot-tapping – Tasks carried out involving filled pipe lines or equipment. Includes work on systems under pressure, or where welding cutting or grinding on on-line equipment is concerned.

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

Restricted Area – Activities that will be carried out in special areas of the facility that requires Management notification.

Permits are posted in a visible location at the work site for the duration of the work.

Completed permits should be kept on file for audit purposes. Generally, about thirty permits should be sufficient.

A list of persons authorized by the site manager to issue and approve permits will be maintained. Each permit has a written program describing its usage and limitations. A list of authorized persons is kept with these programs.

The most effective way to protect our employees from falls is to eliminate the hazard through design if reasonable and feasible. Second, is the use of a collective system that requires employees to work in a safe manner, and third is personal fall protection that requires employee participation.

Collective systems do not require the worker to do or wear anything extra. They work all of the time and in all conditions once they are installed. Examples: Stairways, guardrails, platforms. At a minimum, all collective systems shall consist of a guard rail of a 42” minimum height, 21” mid-rail, and a 4” toe-board.

Where hazards cannot be designed out of a work space, and where collective systems are not feasible, access to work above ground level can be provided by the following equipment, man-lifts (JLG, scissors lift, lift truck platforms), scaffolding, and lastly ladders. All of these methods carry their own hazards which can be lessened through proper use and precautions. For all work over 6’ off the ground (as measured at foot level), all of these methods require the use of supplemental fall protection including full body harness / lanyard. All of these methods also require periodic inspections to insure safe use. At the Acheson Port Huron Site, Ladders are considered the least safe method for accessing overhead work. All other methods should be reviewed prior to using a ladder.

Site Management and those authorized to issue permits will be trained on all aspects of this program. They shall fully understand this program and the procedures for issuing permits to employees and contractors.

Whenever any employee may be exposed to a fall hazard greater than 6 feet (1.83 meters), fall protection is required.  Listed in the table below are identified fall hazards and recommended means to protect our employees.  Options are not listed in order of priority.

Examples of activities, locations and fall protection follow:

ACTIVITIES	NORMAL LOCATIONS	FALL PROTECTION OPTIONS
On top of rail cars, or tank trucks when fall hazard exists.  This includes normal loading/unloading spots and anywhere employees/contractors may have to go on top of a tank truck or rail car.	Rail car loading/unloading spots.  Warehouse, Tank Farm, Eva, Hot Melt or anywhere on NSCC property	1. Personal fall arrest system 2.  Horizontal lifeline with full body harness attached. 3. Full body harness attached to self retracting lanyard 4.  Standard guard-railing
Working out of an aerial platform, i.e.… jlg, cage attached to fork truck, scissors lift	Through-out the plant	1. Personal fall arrest system
Maintenance work at heights six feet or greater.	Throughout the plant	1.  Personal lifting devices such as jlg, cage attached to fork truck, scissors lift, man cages 2.  Scaffold, or ladders 3.  Personal fall arrest system
Walking/working surfaces greater than four feet from ground level.	Throughout the plant	1.  Personal lifting devices such as JLG, cage attached to fork truck, scissors lift, man cages 2.  Standard guard railing 3.  Personal fall arrest system
Tops of tanks	Throughout the plant	1.  Personal fall arrest system 2.  Standard guard-railing 3.  Personnel lifting device.
Edge of  roofs	Roofs	1.  Personal fall arrest system, or restraint system. 2.  Standard guard-railing 3.  Personal lifting device 4.  Safety monitor and warning lines
Platforms	Throughout the plant	1.  Standard guard-railing with self-closing gate or safety chain across access point. 2.  Personal fall arrest system

Falls from any height can cause serious injury and death. It is the policy of Acheson Colloids Company to provide a safe and healthy workplace, and provide a formal written Working at Heights program. Whenever any task would allow a worker to fall 6 feet (1.83 meters) or more, or any distance where the likelihood of a serious injury exists, the hazards of falling must be identified, evaluated, and controlled based on the hierarchy of controls.

This policy is based on the belief that:

• All fall hazards can be eliminated.
• To control fall hazards is morally responsible.
• Implementation of a fall hazard control program is the most effective way to provide a continuous process to identify, evaluate and control fall hazards.

Ladders should be used when other feasible methods of accessing work above 6’ have been exhausted.

Two of the more common causes of falls are using ladders improperly, and using makeshift ladders. Take the time to get the proper ladder for the job and use it properly. Design of all ladders shall be such as to produce a ladder without structural defects or accident hazards such as sharp edges, burrs, etc.

All Ladders

• All employees using ladders shall receive training.
• Each ladder has to be inspected by a competent person every six months (Safety Mechanics). All ladders passing inspection shall have a label affixed to the ladder stating the date and who performed the inspection. Ladder inspection form in Appendix II shall be used as guidance for inspection of all ladders.
  • If a ladder is involved in a tip over it must be inspected before reuse.
• Ladders not inspected in the last year cannot be used.
• The person using the ladder must inspect each ladder visually before each use.
• All defective ladders must be tagged as such and removed from service. (destroyed)
• The spacing of rungs or steps shall be on 12-inch centers.
• Always follow the belt buckle rule: keep your belt buckle within the side-rails of the ladder.
• If the work to be performed from the ladder will take more than fifteen minutes, try to do the job differently. Examples include a scaffold, cage on a forklift, genie, or JLG.
• Three-point contact must be maintained when climbing ladders.
• All sharp points and edges on the surface must be removed or covered.
• Ladders must be maintained in good usable condition at all times.
• When in doubt of what type of ladder to use consult your supervisor.
• The base of the ladder must be placed on secure footing.
• When going up or down a ladder the person climbing must face the ladder.
• All ladders shall have nonconductive side-rails if they are used where employees or the ladder could contact exposed energized parts.
• Wood ladders shall not be painted.

Step Ladders

• Stepladders shall not exceed 20 feet in length. (measured length of the front side rail).
• The bottoms of the four rails are to be supplied with insulating non-slip material for the safety of the user.
• Rungs and steps shall be corrugated, knurled, dimpled, coated with skid-resistant material, or otherwise treated to minimize the possibility of slipping.
• A metal spreader or locking device of sufficient size and strength to securely hold the front and back sections in the open position shall be a component of each stepladder.
• No work shall be done off the top two steps of a stepladder.
• Always follow the belt buckle rule: keep your belt buckle within the side-rails of the ladder.
• If working in front of a doorway always block the door open so no one will open the door and cause a fall.
• If working in a walkway set out cones to alert employees passing by of the potential of falling objects.
• A stepladder shall not be used as a straight ladder.
• When ascending or descending, the climber must face the ladder.
• The back of a stepladder may not be used for climbing.

Straight And Extension Ladders

• The maximum length of individual sections of straight ladders shall not exceed 30 feet (9.14 m), two section ladders shall not exceed 48 feet (14.63 m), and over two-section ladders shall not exceed 60 feet in length.
  • Overlap of ladder sections up to 36 feet (10.97 m) in length shall be at least three feet.
  • Overlap of ladder sections from 36 feet (10.97 m) to 48 feet (14.63 m) shall be four feet.
  • Overlap of ladder sections from 48 to 60 feet (18.29 m) shall be 6 feet (1.83 meters).
• Straight and Extension ladders must extend three feet beyond the landing.
• The minimum width between side rails must be at least 12 inches (30.48 cm).
• Straight and extension ladders must be tied off at the top when in use.
• Person on the ground must hold the ladder while the first person climbs the ladder to tie it off.
• Only one person at a time is allowed on a ladder.
• Always follow the belt buckle rule when working from ladders. Keep your belt buckle within the side-rails.
• Follow the 4 to 1 rule for straight and extension ladders to ensure proper angle. For every four feet up the base should be one foot out at the base.
• Do not use straight ladders as a walkway or platform
• Inspect all ladders before each use.

Inspection
All safety equipment used as fall protection must be inspected prior to each use, by the employee(s) using the equipment. All full body harnesses, lanyards, retractable lanyards, and horizontal lifelines must be inspected annually by a competent person.

Maintenance
Cleaning of all polyester and nylon components of fall arrest systems can only use mild soap and water. No chemicals are allowed for cleaning. The manufacturer must perform any modifications to the equipment.

Maintenance
All stainless steel lifelines and lanyards can be cleaned by spraying WD 40 and wiping it off. Always wear gloves when handling cables.

Any and all fall protection equipment that has been involved in a fall must be turned in to the site Safety Supervisor.

Storage
Store all personnel fall protection equipment in a clean dry location out of direct sunlight. Example, in your locker.

Training
Any employee using fall protection must receive training. This training will be completed during the Department Safety Meeting. Refresher training shall be completed at least every two years. Training shall consist of the following:

• How to inspect the harness
• How to inspect the lanyard
• How to clean & store
• Limitations of equipment
  • weight limits
  • when to discard
  • construction materials
• How to put on harness
• How to attach the lanyard
• Anchor points
• Restraint – Vs – fall arrest system
• What happens during a fall?
• Rescue
• How to calculate fall distance
• Ladder Safety
• Contents of Safety at Heights Program

Scaffolds shall be furnished and erected in accordance with this program and OSHA standard 1910.28, for employees engaged in work that cannot be done safely from the ground.

• All scaffolds must be erected/dismantled under the supervision, or direction of a competent person.
• A competent person shall complete inspection when a scaffold is erected.
• Always dismantle the scaffolding from the top down.
• Lower all components to the ground by rope, hoist, or man to man.
• Never throw the parts to the ground.
• Never leave a partially dismantled scaffold.
• Fall protection is required during the erection of scaffolds unless it creates a greater hazard.
• The front edge of the scaffold platform must be no more than 14 inches (35.56 cm) from the face of the work unless guardrails are used along the front edge and/or a personal fall arrest system is used.
• All scaffolds four feet and higher must be guarded on the sides and back by standard guard-railing, if practical. (fall arrest system may be used if standard guard-railing is not practical)
• When engineering controls such as guardrails and safety nets cannot protect you from fall hazards, then a personal fall arrest system must be used at heights greater than four feet.
• The footing for scaffolds must be sound, rigid, and capable of carrying the maximum intended load without settling or displacement.
• Unstable objects such as barrels, boxes, loose bricks, or concrete blocks shall not be used to support scaffolds.
• Scaffolds and components shall be capable of supporting without failure four times the maximum intended load.
• Scaffolds must be maintained in safe condition.
• Scaffolds must not be altered or moved horizontally while they are in use or occupied.
• Any scaffold damaged or weakened from any cause must be immediately repaired and shall not be used until repairs have been completed.
• Scaffolds shall not be loaded in excess of the working load for which they are intended.
• All planking shall be scaffold grade.
• Nails or bolts used in the construction of scaffolds shall be of adequate size and in sufficient numbers at each connection to develop the designed strength of the scaffold.
• All planking or platforms shall be overlapped at least 12 inches (30.48 cm), or secured from movement.
• Safe means of access to reach the working level shall be provided.
• Never climb the cross-bracing of a scaffold.
• Scaffold planks must extend over their end supports not less than 6 inches (15.24 cm), nor more than 18 inches (45.72 cm).
• The poles, legs, or uprights of scaffolds shall be plumb, secure and rigidly braced to prevent swaying and displacement.
• Materials being hoisted onto a scaffold shall have a tag line.
• Overhead protection shall be provided for employees on a scaffold if they are exposed to overhead hazards.
• Where employees are required to work or pass under scaffolds the scaffold must have a screen between the toe-board and the guardrail, extending along the entire opening.
• No employees may work outside on a scaffold during storms or high winds.
• No employees may work on a scaffold, which are covered with ice or snow.
• Housekeeping must prevent the accumulation of tools, debris and materials in quantities that may cause a hazard.

 

• All roof access points must be posted as “Authorized Personnel Only, Inform Supervisor and Operator before Entry. If used as an emergency exit it must be posted as such.

  Supervisor must approve all entry onto roofs.

• Roof entrants must be in radio or phone contact with their Acheson Colloids contact or their supervisor.
• Any work taking place within six feet of an edge must use one of the following methods to prevent injury before the job takes place.
  • Installation of guardrails
  • A restraint system that prevents employee(s) from reaching the edge.
  • Full body harness with shock absorbing lanyard attached to a suitable anchor point capable of arresting the fall.
  • Horizontal lifeline, harness and lanyard.
  • Warning lines with a safety monitor.
  • Other approved means