Work Permit Procedure 2021

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Document # HSE/ HSE - Safety – SSM - II - 008 Date Prepared: May 2014

Page 1 of 107
Revision: 05 Date Revised: 31st March 2021

Work Permit Procedure

AUTHORIZATION:

Revised By: ____________________________ Reviewed By: ____________________________


Ameer Hamza Syed Salwat Hosain Rizvi
Process Safety Engineer Safety Manager

Reviewed By: ________________________ Approved By: ___________ _____________


Aqeel Riaz Mahmood Siddiqui
GM HSE&T VP Manufacturing

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


Document # HSE/ HSE - Safety – SSM - II - 008 Date Prepared: May 2014
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Revision: 05 Date Revised: 31st March 2021

Change Record:
All changes have been made Bold, Italic and Highlighted in Grey

Sr. Date Rev. Page & Change Description


# # Section
Section

01 May’11 01 All Procedure has been revised and document format changed

• Procedure has been revised and document format changed


• LOTOTOTO guidelines has been updated
• Classified Area definition has been revised
• Primary Authorized Employee definition has been revised
• Tagging Procedure – Blind tags guidelines incorporated
Multiple
02 May’14 02 • Allowable Concentrations for Entry into Vessels
sections
• Test Out Procedure Defined
• Lock Colors/ Tags revised
• Valve LOTO Guidelines incorporated
• Work Permit Training & Certification Guidelines
• Multiple other changes

• Procedure has been revised and document format changed


• PSRM references have been revised to PSM
• Permit initiator and Shift supervisor references have been removed
• Marked P&ID, Rescue Plan and Gas Test Logging incorporated
Multiple • Grinder Inspection protocol incorporated
03 July’17 03
sections • PVC / PM&S Interface work permit protocol
• WORK PERMIT EXCEPTION FOR PM&S
• Work Permit Certification Guidelines for Employees Rejoining and Cl-25
& Above incorporated
• Multiple other changes

• Format Revised as per QM-01 Rev -12 and document code change from
Multiple
04 Dec’17 04 HSE / Safety/ Level II/ SSM/ 008 to HSE-Safety–SSM-II-008
Sections
• Skill certification clarification added for production department

05 Mar’21 05 23 Interconnecting Unit Protocol Revision

Multiple
06 Mar’21 05 Employee P. No provision on permits
sections

07 Mar’21 05 34 Job authorizations on Single permit

08 Mar’21 05 101 Permit Certification for non-technical employees

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


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09 Mar’21 05 44 Hot Permits Dos & Don’ts

10 Mar’21 05 44 Hot Permit for Photography

11 Mar’21 05 42 Hot Permit for JBs Door opening

12 Mar’21 05 42 Non-IS Equipment in Classified Area

13 Mar’21 05 105 Waivers of TA-2020 in Appendix

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


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Revision: 05 Date Revised: 31st March 2021

SECTION-1 TABLE OF CONTENTS


SECTION-1 TABLE OF CONTENTS ..................................................................................................... 4
SECTION-2 WORK PERMIT PHILOSOPHY ......................................................................................... 7
2.1 SCOPE: ........................................................................................................................................... 7
2.2 PURPOSE ........................................................................................................................................ 7
2.3 SUMMARY ....................................................................................................................................... 7
SECTION-3 DEFINITIONS AND ABBREVIATIONS.............................................................................. 9
3.1 AFFECTED PERSON ......................................................................................................................... 9
3.2 AGITATED EQUIPMENT ..................................................................................................................... 9
3.3 AUTHORIZED EMPLOYEE .................................................................................................................. 9
3.4 BATTERY LIMIT ................................................................................................................................ 9
3.5 CLASSIFIED (HAZARDOUS) AREA ...................................................................................................... 9
3.6 CONFINED SPACE .......................................................................................................................... 10
3.7 ENERGY-ISOLATING DEVICE ........................................................................................................... 10
3.8 LIFT OVER PROCESS LINES OR EQUIPMENT .................................................................................... 10
3.9 LOCK OUT DEVICE/ MULTIPLE LOCK DEVICE .................................................................................... 10
3.10 MAINTENANCE PERSON ................................................................................................................. 10
3.11 NON PERMIT CONFINED SPACE (NON- PERMIT SPACE) ..................................................................... 10
3.12 PRIMARY AUTHORIZED EMPLOYEE ................................................................................................. 10
3.13 PRINCIPLE AUTHORIZED EMPLOYEE ............................................................................................... 11
3.14 SERIOUS PROCESS SAFETY INCIDENT ............................................................................................ 11
3.15 ALL PERSONNEL ............................................................................................................................ 11
3.16 SYSTEM ........................................................................................................................................ 11
3.17 OPENING LINES AND EQUIPMENT.................................................................................................... 11
3.18 HAZARDOUS MATERIAL .................................................................................................................. 11
3.19 PROCESS OR PROCESS MATERIAL ................................................................................................. 12
3.20 STORED ENERGY .......................................................................................................................... 12
3.21 ISOLATED ...................................................................................................................................... 12
3.22 CLEARED ...................................................................................................................................... 12
3.23 VERIFIED....................................................................................................................................... 13
3.24 LOCKOUT PROTOCOL..................................................................................................................... 13
3.25 TURNAROUND LOCKOUTS .............................................................................................................. 14
3.26 ABBREVIATIONS ............................................................................................................................. 14
SECTION-4 GENERAL REQUIREMENTS .......................................................................................... 15
4.1 OVERVIEW .................................................................................................................................... 15
4.2 TIME LIMITS................................................................................................................................... 19
4.3 JOBS BY AREA OWNER .................................................................................................................. 19
4.4 GAS TESTING ................................................................................................................................ 20
4.5 PERMITS FOR MORE THAN ONE JOB ................................................................................................ 20
4.6 RETENTION OF PERMITS ................................................................................................................ 21
4.7 ENTERING OPERATING UNITS......................................................................................................... 21
4.8 PERMIT & JOB PREPARATIONS IN NIGHT SHIFT FOR EXECUTION IN DAY SHIFT.................................. 21
4.9 EXCEPTIONS ................................................................................................................................. 22
4.10 UNIT ENTRY / EXIT PROTOCOL ....................................................................................................... 22
4.11 BLIND TAGS .................................................................................................................................. 22
4.12 INTER-UNIT ISOLATION PROTOCOL.................................................................................................. 23
A PROCEDURE FOR ISOLATION OF INTER-UNIT CONNECTING ELECTRICAL BREAKERS .............................. 24
B PROCEDURE FOR ISOLATION OF INTER-UNIT CONNECTING PROCESS PIPELINES................................... 25
C EXAMPLES OF INTER-CONNECTING LINKS AT SITE ................................................................................ 26
SECTION-5 ROLES & RESPONSIBILITIES IN PERMIT WORKFLOW ............................................. 27
5.1 PRIMARY AUTHORIZED PERSON (AREA OWNER) ............................................................................. 27
5.2 PRINCIPLE AUTHORIZED PERSON (MAINTENANCE PERSON)............................................................. 27

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


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5.3 RESPONSIBILITIES FOR EXCAVATION WORK PERMIT ........................................................................ 28


5.4 ACCOUNTABILITY ........................................................................................................................... 29
SECTION-6 PERMIT ISSUANCE WORKFLOW .................................................................................. 30
6.1 SPARE / REDUNDANT BREAKERS / CUBICLES .................................................................................. 32
6.2 MAINTENANCE OF POWER-DRIVEN EQUIPMENT IN WORKSHOPS........................................................ 32
6.3 PERSON AUTHORIZED TO ISSUE WORK PERMIT ............................................................................... 32
6.4 WORK ON ENERGIZED EQUIPMENT: ................................................................................................. 33
6.5 WORK ON SAFETY CRITICAL DEVICES / INSTRUMENTATION / EQUIPMENT: .......................................... 33
6.6 WORK ON NON-SAFETY CRITICAL DEVICES / INSTRUMENTATION /EQUIPMENT: .................................. 34
6.7 JOBS AUTHORIZATIONS ON SINGLE PERMIT .................................................................................... 34
6.8 PROTOCOL FOR OFF HOURS WORK PERMIT ISSUANCE ................................................................... 35
SECTION-7 JOBS IN NON-OPERATING AREA ................................................................................. 36
7.1 NON-OPERATING AREAS WORK PERMITS RULE.......................................................................... 36
SECTION-8 PERMIT AREA ROAD MAP ............................................................................................. 37
SECTION-9 TYPES OF WORK PERMITS ........................................................................................... 38
9.1 COLD WORK PERMIT (GREEN CARD).............................................................................................. 38
9.2 HOT WORK PERMIT (RED CARD) .................................................................................................... 39
9.3 ELECTRICAL WORK PERMIT (PINK CARD) ....................................................................................... 46
9.4 INSTRUMENT WORK PERMIT (PURPLE CARD) .................................................................................. 49
9.5 CONFINED SPACE ENTRY PERMIT (LIGHT BLUE CARD) .................................................................... 51
9.6 EXCAVATION AND CIVIL WORK PERMIT (WHITE CARD) .................................................................... 71
9.7 VEHICLE ENTRY PERMIT (LUMINOUS ORANGE CARD) ...................................................................... 74
9.8 LIFTING OVER PROCESS EQUIPMENT PERMIT (NAVY BLUE CARD) ................................................... 76
9.9 RADIOGRAPHY WORK PERMIT (YELLOW CARD) .............................................................................. 78
9.10 OTHER WORK PERMIT EXCEPTIONS: .............................................................................................. 80
9.11 BLANKET PERMITS:........................................................................................................................ 80
9.12 WORK PERMIT PROTOCOLS FOR PM&S: ........................................................................................ 82
SECTION-10 LOCKOUT, TAGOUT, TRYOUT & TESTOUT ................................................................. 83
10.1 INTRODUCTION .............................................................................................................................. 83
10.2 PRINCIPLES ................................................................................................................................... 83
10.3 KEY ELEMENTS ............................................................................................................................. 84
10.4 LOTOTOTO GENERAL REQUIREMENTS......................................................................................... 84
10.5 DEPARTMENT LOCKS AND TAGS ..................................................................................................... 85
10.6 ELECTRICAL LOTOTOTO ............................................................................................................. 87
10.7 STORED CHEMICAL ENERGY LOTOTO .......................................................................................... 90
10.8 VALVE LOTOTO SPECIFIC GUIDELINES ......................................................................................... 94
SECTION-11 PERSONAL PROTECTIVE EQUIPMENT (PPE) ............................................................. 97
11.1 PRINCIPLE ..................................................................................................................................... 97
11.2 RELAXATION / PPE REMOVAL ........................................................................................................ 97
11.3 THE UNEXPECTED ......................................................................................................................... 98
SECTION-12 WORK PERMIT TRAINING & AUDITING........................................................................ 99
12.1 GAS TESTING ................................................................................................................................ 99
12.2 CONFINED SPACE RESCUE TEAM ................................................................................................... 99
12.3 SCAFFOLDING CERTIFICATION ...................................................................................................... 100
12.4 WORK PERMIT AUDIT................................................................................................................... 100
SECTION-13 WORK PERMIT SKILL CERTIFICATION ...................................................................... 101
13.1 PURPOSE ................................................................................................................................. 101
13.2 REQUIREMENT ........................................................................................................................ 101
13.3 PSM CERTIFICATION ................................................................................................................... 101
13.4 PERMIT CERTIFICATION FOR NON-TECHNICAL EMPLOYEES............................................................ 101
13.5 WORK PERMIT STUDY & TRAINING OF THE EMPLOYEE .................................................................... 102
13.6 WORK PERMIT ELECTRONIC TEST. ................................................................................................ 102

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


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13.7 WORK PERMIT TEST FOR DUMMY RUN........................................................................................... 102


13.8 WORK PERMIT FINAL INTERVIEW OF THE INDIVIDUAL FOR CERTIFICATION ........................................ 102
13.9 WORK PERMIT SKILL CERTIFICATION COMMUNICATION & RECORD ................................................ 103
SECTION-14 WORK PERMIT REVISION PROTOCOL ...................................................................... 104
SECTION-15 APPENDIX ...................................................................................................................... 105
15.1 PERMIT WAIVERS OF TA-2020 ..................................................................................................... 105

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


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SECTION-2 WORK PERMIT PHILOSOPHY


2.1 Scope:
This manual is applicable to EPCL Chlore Vinyl manufacturing site. This includes EDC-VCM, CA
PVC-I/II/III, Utility/Power Plant (new facilities and old facilities), VCM/Ethylene import line, PM&S,
Warehouses , Training facilities, Laboratories, All Buildings, Scrap yard, Pallet yard and Off-Spec
yard, E pond including Neutralization pits, Plant Internal Roads, Hydrogen export line to Linde,
EVTL Power Export line and Raw water line.

2.2 Purpose
1. The purpose of a Work Permit system is to ensure that jobs are safely planned, equipment
is properly prepared, employees are adequately informed, and work is safely executed.
The responsibility of safety is shared by all involved in the job covered by the Work Permit
system.
2. This procedure also assures the personal safety of all individuals involved in the opening
of piping systems and to safeguard against potential environmental releases.
3. This document stems out from PSM 15, Procedure & Performance Standard, which
requires that a system should be in place to ensure that all the manufacturing activities
are done safely by establishing and following practices for safe work.
4. “Work permit is an authorization given by approved, designated person of area owner to
relevant interfaces to work in respective areas with a given time limit and as per specific
conditions which were marked on the work permit.”
5. This procedure has been developed and revised based on OSHA Guidelines, GHSE
direction, Incident learnings and benchmark with affiliates.

2.3 Summary
The Work Permit system shall encompass the following:

1. The Work Permit system should provide for a Work Permit document or form(s) which
is used as a tool to:
• Describe the type of work.
• Specifically identify the area and equipment where work is to be performed.
• Ensure that the work area has been properly prepared and inspected for the specific
task before the work is started.

2. The Work Permit system should separately address the permit requirements for different
categories of work and cover the following aspects:
• Opening of process equipment and piping.
• Lock-out / Tag-out / Try-out / Test-Out of hazardous energy sources.

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


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• Control of ignition sources (Hot Work Permit). Permits shall be issued for all hot
work, except for areas exempted by Manufacturing HSE e.g., in mechanical workshops
etc.
• Entry into confined spaces.
• Movement of heavy equipment relative to equipment containing hazardous materials
(Including lifting over process pipelines)
• Electrical / Instrument jobs.
• Radiography
• Vehicle entry
• Excavation and civil jobs
• Lifting over
• Specify time limits of the permit.
• Evaluate the need for a JSA.
• Designate if a gas test is needed type of test, time, and results of explosivity etc.
• Specify standby equipment, personnel, and any special precautions, such as protective
equipment, hazardous materials monitoring, etc.
• Ownership of various areas of the Site for the Work Permit should be clearly assigned.
• For the protection of individuals working on different systems, detailed procedures
dealing with the specific hazards should be made part of the Work Permit system.
• Training and certification requirements should be clearly specified.
• Audit of the Work Permit process should be conducted to ensure compliance with
the procedure and to see that the procedures in place are meeting the requirements
of safe operations.
• Defining pertinent terms for uniformity of understanding, such as breaking into lines
(e.g. flange and/or union opening etc.), hazardous material or process hazard, system
isolation, process, stored energy, and cleared (thru flushing, purging etc.).
• Establishing work based on the condition of the system or equipment on which work
is to be done.
• Defining the minimum procedural requirements for work in various conditions.
• Providing guidelines when setting up systems for maintenance work including lock
out/Tag out/Try out/ Test out procedure for process equipment/valves.

Note: In all the cases mentioned above, the permit shall be issued to EPCL’s work permit
certified employees only. Selected Contractor supervisors are being authorized by EPCL HSE
department with GM HSE review and after HSE Manufacturing approval to receive only cold
work permit (not involved SCD & MOC) for job execution at Site, however overall job safety
will continue to be the responsibility of Maintenance Engineer.

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


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SECTION-3 DEFINITIONS AND ABBREVIATIONS


3.1 Affected Person
Affected Person is anyone else who works in an area where lockout is performed, but who does
not put a lockout device is considered as an Affected Person. At EPCL Contractor employees,
Trade Apprentices and Graduate Trainee Engineers would be considered in this category.

3.2 Agitated Equipment


It means all vessels or spaces that contain rotating parts.

3.3 Authorized Employee


Anyone who affixes a lock / tag or who is involved in lockout is called an Authorized.
Employee. All EPCL / Contractor (Approved by MHSE) employees who have qualified the test
on work permit procedure fall in this category.

3.4 Battery Limit


The battery limits are defined as the plant area up to the roads around a particular plant.

3.5 Classified (Hazardous) Area


• The type of hazard is one which is created by the presence of flammable gases or vapors
in the air, such as natural gas, VCM, Ethylene, Hydrogen, or EDC etc. When these
materials are found in the atmosphere, a potential for explosion exists, which could be
ignited if an electrical or other source of ignition is present.

• In addition to the types of classified (hazardous) locations, code (Classified area) also
concerns itself with the kinds of conditions under which these hazards are present. The
Code specifies that hazardous material may exist in several different kinds of conditions
which, for simplicity, can be described as, first, normal conditions, and Second abnormal
conditions.

• In the normal condition, the hazard would be expected to be present in everyday


production operations or during frequent repair and maintenance activity. When the
hazardous material is expected to be confined within closed containers or closed systems
and will be present only through accidental rupture, breakage or unusual faulty operation,
the situation could be called "abnormal."

Note: All classified areas are defined in PSI package of every unit.

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


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3.6 Confined space


It is a location that:
• Is large enough and so configured that an employee can enter and perform assigned work.
• Has limited or restricted means for entry or exit.
• Is not designed for continuous employee occupancy.
Examples include:
• Tanks, vessels, hoppers, manholes, under equipment i.e. below furnace, HRSG etc
including any piping large enough to enter.
• Pits, dikes, ditches, or excavations more than 04 feet deep or pits greater than 04 feet
deep that require personnel to work with their heads below the rim.

3.7 Energy-isolating device


It is a physical means of isolating or controlling hazardous energy, such as an electrical breaker.

3.8 Lift Over Process Lines or Equipment


It occurs when the load, or any portion of the crane boom used in the lift, is suspended over
process piping or equipment inventoried with process materials.

3.9 Lock out device/ Multiple Lock Device


It is a padlock with key. Additionally, multiple lock device is used to place 3 or more locks on a
single breaker.

3.10 Maintenance Person


Any person assigned to work on a particular job or portion of a job, other than the routine
operation job is known as the Maintenance Person.

3.11 Non permit Confined Space (non- permit space)


It is a location that does not contain or have the potential to contain any hazards except
atmospheric hazards and these hazards are not capable of causing death or serious physical harm
(some dikes, most excavations etc.).

3.12 Primary Authorized Employee


The Primary authorized employee is the one who exercises overall responsibility for adherence
to the company lock out/tag out/ try out & test out procedure .

In EPCL, Shift In-charge who has qualified the Board review and qualified the test on work permit
procedure falls in this category. The SIC may designate a Process Operator for energy
isolation/lock out/ & tag out if the Process Operator has been independently assigned a “Post”
(after certification) and has qualified the test on work permit procedure.

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


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3.13 Principle Authorized Employee


An authorized employee who supervises or leads a group of servicing / maintenance employees
is called a Principle Authorized Employee.

At EPCL, maintenance supervisors or lead person (Mechanical, I/E, etc.) who have qualified the
test on work permit procedure fall in this category.

3.14 Serious Process Safety Incident


It is an incident on or off the site with the potential for any of the following: multiple serious
injuries, significant explosion, significant fire, or significant release of chemicals.

3.15 All Personnel


Includes operations, maintenance, I&E, Projects and contractor personnel, including
Supervision.

3.16 System
One or more pieces of equipment, piping, vessels, tubing, which are grouped for the purpose of
isolation and clearing, on which work is to be done.

3.17 Opening Lines and Equipment


The removal of mechanical restraints to open an integrated piping, hoses or equipment system
to the atmosphere. These openings include and are not limited to the following:
• Disconnecting pipelines/flanges/cutting of lines
• Disconnecting tubing
• Disconnecting loading and unloading hoses
• Disconnecting service to process
• Opening equipment, such as pumps, compressors, fans, process equipment, drums, ports,
etc.
• Opening vents and drains.
• Removing blind flanges, plugs, caps, etc., from drain and vent valves.
• Any other openings under conditions where absence of hazardous material has not been
verified.
• Removal of pressure gauges.
• Transmitter Tubing

3.18 Hazardous Material


Any material, radioactive source or stored energy which can be within or outside the system on
which work is to be done, which can cause injury or adverse health effects if released. The
Hazardous Material List for each area will be defined using the definitions below.

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• Hot or Cold Materials - Materials which cause thermal burns or frostbite. This includes
materials above 120° F (49° C) or cold materials, colder than 32° F (0° C).e.g. steam
condensate and chilled Freon.
• Corrosives - Materials such as acids and caustic which cause chemical burns.
• Toxic Materials - Materials which if ingested or absorbed through the skin or respiratory
system can cause illness.
• Pressurized Materials - Materials that by nature are not hazardous but can be hazardous
when under pressure or Material with any other stored energy
• Irritants - Any material known to be a skin, eye or respiratory irritant.
• Radioactive Material - Radioactive source.
• Carcinogens - Substances which are related to the generation of cancer.
• Flammables - Materials which will readily burn (Flash point less than 100° F).
• Combustibles - Materials which will burn (Flash point greater than 100° F).
• Pyrophoric - A substance that ignites spontaneously in air at or below 54 °C or within 5
minutes after coming into contact with air

3.19 Process or Process Material


Any solid, liquid or gas which can be in the system where work is to be done. For purposes of
this procedure, radioactive sources are process material.

3.20 Stored Energy


A property of various kinds of material by which, under certain circumstances, the material can
cause change by itself without a person starting it or controlling it. As per OSHA
((1910.147(c)(1)), Any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal,
or other energy are fall under stored energy source. Some common examples are capacitors,
accumulators, springs, high voltage, pressurized system, batteries, catalyst at various
temperatures, elevated weight, any material at elevated temperature, process materials that may
react when exposed to atmosphere, hydraulic or mechanical energy etc.

3.21 Isolated
A system is considered isolated when the following three conditions are complete:
• Hazardous material is prevented from getting into or around a system by mechanical,
physical, or electrical means.
• A mechanical or electrical system is de-energized and prevented from operating by
mechanical or electrical methods. All energy sources are to be locked.
• The system is isolated from all external sources of hazardous material or stored energy.

3.22 Cleared
A system is considered cleared (purged, flushed & drained) when the following two conditions
are met:

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• All hazardous material and stored energy within the system has been removed or made
non-hazardous. This is accomplished by flushing or purging through the system from one
end to the other for process materials which are volatile or soluble. If 100% of the system
cannot be flushed or purged from one end to the other end, then the system is not
cleared. Every effort must be made to insure that flushing of the entire system is complete
with precautions taken to stroke/tap or open automatic and manual valves to avoid any
material being trapped in the valve core or between the body and adjacent flange or blinds.

• The system is isolated from the source of hazardous material and such material is
prevented from re-entering the system.

Note: Choking of drain/ bleeder to be confirmed by operation with full PPE’s.

3.23 Verified
A piping system is considered verified clear when the absence of hazardous material can be
certified. Verification may be determined by one or more of the following examples.
• Pressure gauges (Aids in verification)
• Temperature gauges, pressure gauges cannot be solely relied upon.
• Temperatures check up by laser gun.
• PH of fluid.
• Open vents and drains which do not flow or weep after assuring they are not plugged or
restricted.
• Visual inspection.
• Demonstrate by trying switches, vents, drains/bleeders etc.

3.24 Lockout Protocol


1. The owner that prepared the system for repair and the maintenance personnel that are
to make the line opening/repair would sign the relevant permit. Signature means that the
individuals involved have reviewed the job plan/permit and have field-verified the lockout
and drain points and deem it adequate to complete the job without incident.
2. Both the owner and all members of the work group involved in the opening/repair must
install field locks and tags together. The owner (Production) must perform the "Try" steps
in the presence of a member/members of the work group (Maintenance/projects etc.)
3. A member of the work group i.e., maintenance interface (Principle Authorized Employee)
will retain the "Work Permit" at the job site until the work is complete.

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


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3.25 Turnaround Lockouts


1. Maintenance personnel and owner involved in the line entry must review the job
plan/permit requirements and sign the permit to signify understanding and field verify the
boundaries of the lockout in relation to the task assigned.
2. The owner (Primary Authorized Employee) and Principle Authorized Employee (member
of the work group) involved must sign the permit and field-verify the lockout. Lockout/Tag
out protocol for Turnaround/Shut down would be as followed.
3. Management of red locks will be done in field offices of respective unit instead of CCR.
(Same protocol will be followed for PVC Grade change activities but for that dedicated
box and locks should be present all the time in field office)

3.26 Abbreviations
HSE Health, Safety and Environment PSSR Pre-Startup Safety Review
JSA Job Safety Analysis PSM Process Safety Management
MOC Management of Change PHA Process Hazard Analysis
OSHA Occupational Safety and Health SOP Standard Operating Procedure
SIC Shift In-charge GT Gas Turbine
PPE Personal Protective Equipment JCC Job Cycle Check
NEQS Sindh Environment and Quality Standards
SCD Safety Critical Device GHSE Group HSE

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SECTION-4 GENERAL REQUIREMENTS


The fundamental purpose of the Work Permit is to safeguard the worker, protect the plant
equipment, prevent fire and in general to ensure that all work is carried out under the safest
possible conditions. A permit must be issued for all jobs which are to be carried out by non-
production personnel and contractors. It fixes responsibilities of each party for the work to be
done.

Additionally, it serves the following objectives:


1. By issuing a Work Permit, the production personnel are aware that mechanical, electrical,
and/or other work is in progress at a specific location in the plant and the process
equipment to be worked on including immediate surrounding areas are in a safe condition
for the work to proceed.

2. Should the prevailing conditions of the area or equipment in which the work is to be done
change or operational changes be made which would endanger the safe working
conditions which previously existed, the work should be stopped immediately by the
person responsible for issuing the Work Permit, or his designate who will withdraw the
permit and working technicians.

3. The permit will not be re-issued until safe conditions prevail again.

4. Working in an area where flammable, toxic or corrosive materials are involved presents
special risks which only close supervision and a high degree of cooperation between
Production and Maintenance or other interfaces can minimize.

EPCL's Work Permit system has been designed to provide close contact and high degree of
cooperation necessary between Production and Maintenance and / or other concerned interfaces
for safe and efficient execution of the jobs. Changes to the Work Permit system must be reviewed
and approved by the Manufacturing HSE with notification to all concerned.

4.1 Overview
The Work Permit procedure covers most of the cases. However, special cases will no doubt
arise, which are not specifically covered. While such occurrences, in the absence of definite rules
and regulations, must necessarily be dealt with as special cases, the procedures given herein
should be used as a guideline under such circumstances.

• The appropriate Work Permit must be obtained before any job is started in the Plant except
in areas specially exempted as described in Exemptions.

• There are nine types of Work Permits issued on the Plant:


✓ Cold (Green Card)
✓ Hot (Red Card)

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✓ Electrical (Pink Card)


✓ Instrument (Purple Card)
✓ Radiography (Yellow Card)
✓ Confined Space Entry (Light Blue Card)
✓ Vehicle Entry (Luminous Orange Card)
✓ Excavation and Civil Work (White Card)
✓ Lifting Over Process Equipment (Navy Blue Card)

• Planned jobs should be reviewed and approved by Manager or SIC in daily planning meeting
with interfaces.

• In addition to the Confined Space Entry permit a separate Cold or Hot Work Permit must
also be issued for the actual job that is to be carried out.

• In case a job requires the use of a vehicle such as crane, forklift or pay loader inside the plant
battery limit, a Vehicle Entry Work Permit must be obtained. If the actual job performed by
the vehicle requires lifting, a separate Lifting over Process Equipment work permit must be
obtained. It must be noted that no Separate Cold Work Permit is required in addition to the
Lifting over Process Equipment Work Permit when a job is being carried out by using a crane
or fork lifter.

• In case the vehicle is to perform a job such as transfer of material (lube oil, chemical, etc.)
inside plant battery limits in which no lifting is involved, only the Vehicle Entry Work Permit
would be required. However, the description should clearly state that the permit is being
issued for transfer of material. For example: “Transfer of lube oil drums at Utilities-II using
Forklift.”

• Work Permits are valid only for the time for which they are issued. If work is not started or
is stopped for any period, due to safety considerations, the permit must be withdrawn. After
establishing safe conditions, a fresh permit will be issued, before the work is started or
resumed.

• If the work is delayed or stopped due any reason for over two hours from take over time,
the person In-charge of the job must surrender the Work Permit and take a fresh Work
Permit before job is resumed.

• Appropriate work permits shall be issued for taking readings / monitoring of critical
instruments such as Bentley Nevada panels in Control room or device / instruments (laptop
etc.) plugged-in with plant existing system.

• However, no permit is required for taking readings from DCS/ SCADA or from connected
device / instruments (laptop etc.) or getting verbal reading from Boardman by responsible
individuals. This activity should be carried out with the consent of relevant SIC.

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• It is MANDATORY to sign the work permit properly, and Employee no. should be clearly
mentioned. Maintenance / other interfaces must write job take over time as well.

• Alteration/addition/ over writing on the Work Permit make the permit invalid.

• Work Permits must be closed properly, and it is the responsibility of the Maintenance Person
to notify the Authorized Person when the job is complete. The authorized person is
responsible to ensure all the permits are closed properly.

• The HARD and WHITE copies will then be exchanged after signatures of Post Operator and
Maintenance Person. The copies should also be exchanged if the permit expires/cannot be
extended, or the job is incomplete.

• If the permit acceptor is not present due to any reason or shift changeover, then the person
of same designate or person having valid work permit certification from respective
department can close that permit on behalf of permit acceptor (maintenance person).

• If scaffolding is required to work at an elevated location, it should meet the safety standards
on scaffolds. All scaffoldings will be inspected / approved by the authorized / certified
personnel (EPCL Employee) before use (No authorized employee shall certify the scaffolding
for the job under his direct supervision).

• During scaffolding certification, all inspectors should check the wooden planks as well. It is
mandatory to ensure integrity of wooden plank.

• Use of safety harness is mandatory in a condition or situation which could result in a fall from
an elevated position where handrail/mid rail system are not present. As a guideline, safety
harness is required five feet above grade level except when working on proper scaffolding or
permanent work platforms.

• The scaffolding certificate should be displayed at the scaffolding ladder as specified in the
procedure for scaffolding. The approving supervisor should mention the location, date and
his name along with his signatures on the scaffolding tag. The scaffolding will be certified
following the guidelines given at the back of scaffolding certificate.

Note: Before issuing the scaffolding adjustment permit, it is the responsibility of the Area
Owner (i.e., SIC) to remove the certified scaffolding tag and place “Do not use this Scaffolding”
tag.

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Red Tag Yellow Tag Green Tag

Caution: The “Do Not Use This Scaffolding” tag should be displayed on the Scaffolding if it is
incomplete, unsafe, substandard, expired or yet to be certified by Scaffolding Erecting job
executor. In case a scaffolding gets expired after defined time it should be recertified and tag to
be removed by respective area owner if no job in in progress. DONOT USE this Scaffolding
tag to be placed on such scaffolding by the Area owner.

• Work Permit will be issued to EPCL employees only who have qualified the test on Work
Permit procedure. Any exceptions to this rule must be granted by MHSE. For certain specified
jobs which requires cold work permit; certain contractors are eligible to handle cold work
permits (not involving SCD & MOC) after qualifying EPCL’s Work Permit Test and obtaining
MHSE’s approval. The list of such work permit qualified contractors must be always available
in respective control rooms and cold work permits (not involving SCD & MOC) should only
be issued for the specified jobs. But all responsibilities for safe work practices lie with EPCL
supervisors.

• While authorizing tie-in to the existing facility, no permit will be issued without involvement,
understanding and presence of relevant interfaces and tagging/marking of the line. Direct
supervision by all concerned is mandatory while carrying out such activity.

• Jobs Qualification Guidelines:


o Certified Contractors (approved by MHSE) shall be allowed only to perform Jobs under
EPCL Supervision. Certified Contractor Employee are not eligible to handle any work
permits, except cold work permits handling (not involving SCD & MOC)
o Refresher Training after every 3 years

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• Serious Work Permit violation by the contractor may lead to Cancellation of Certification.
Recertification shall be approved by MHSE.

4.2 Time Limits


1. Permits become void at the expiry time written on the permit when issued. The maximum
time for a permit to be valid is one Operations shift.

2. Note: One hour shift overlap time can be given on permit wherever required for example
M/S can issue permit till 2000 hrs. and N/S can issue permit till 0800 hr.

3. If the work is not completed during the time for which the permit was issued, the person
responsible for performing the work should get it revalidated. It is also the responsibility
of the post operator/Production supervisor/SIC to ensure that the Work Permit is
revalidated without undue stoppage of work.

4. Extension of the permit must be done in the field by the incoming Shift Supervisor, within
one hour of start of the shift. A Work Permit can be extended only once except for the
Confined Space Entry and Hot Work Permit which cannot be extended. The permit shall
be displayed at a conspicuous place close to the work areas (it is being recommended
that permit should be displayed at ground level of equipment under maintenance).

5. Permits may be passed from one Maintenance Person to another on a succeeding shift or
for continuing work for a 24 hours period, provided the relieving Maintenance Person is
doing the same work in the same location for which the original permit was issued. The
confined space entry/Hot work permit cannot be extended beyond one shift and fresh
permit must be issued.

6. However, if SBM/EPCL Supervisors are retained in field during shift change over timings
and all the requirements for working on Hot work/confined space are complied with, the
job may continue beyond the shift, during which new permit should be issued after fulfilling
necessary checks.

7. In case Work Permit is extended, the name of incoming Post Operator / maintenance
technician must be mentioned on the permit and the permit has to be signed by the
incoming person.

8. In forced outage or turnaround, Prod manager may request for 2 hours work permit
extension from MHSE Chairman. It can be granted after GM HSE recommendation.

4.3 Jobs by Area Owner


There are certain jobs which are conducted by Contractor employees and supervised directly by
Area Owner.

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1. These jobs may include office renovation, washroom maintenance, Painting/tagging jobs in
the field, vehicle entry, floor repair work and certain specialized housekeeping jobs etc.

2. In such cases, relevant Work Permit will be approved by Shift In-charge/ Area Owner and
relevant Area engineer/ Area Owner Designate will act as maintenance person (permit
acceptor). However, permit approving personnel cannot sign in place of maintenance
person.
Note:
• Area Owner shall mention all such activities that will require above mentioned work permit.
List approved by the GM Department should be available.
• Lab Sampling/Chemical preparations by USL’s or contractor employees are strictly
prohibited in Process Area.

4.4 Gas Testing


• Gas testing should be done by the employees who have been formally trained, tested and
approved by the Management.
• Updated records of the individuals should be maintained and displayed in the Control Room
or shall be available on LAN.

4.5 Permits for more than one Job


A Cold Work Permit may be issued to a Maintenance Person to cover a number of jobs on single
Process Operating Post (like F.E Area Engineer, Area 100, Area 1400, & Area 1), provided the
work is of the following type:
1. Collection of samples by trained non-production personnel.
2. TMP data collection jobs ( collection of samples & Temp. flow, pressure etc.
measurement)
3. Re-lamping of Tube/Bulb lights.
4. Greasing of machines / motors (except safety critical pumps & wherever LOTOTOTO
required).
5. Tagging of equipment’s / motors in presence of EPCL electrician / FM Tech.
6. Installation Temporary lights / lamps
7. Preventive Maintenance Inspection
8. Routine checking and surveillance of the machines (where LOTOTOTO is not required)
9. Inspection of grounding clamps, cables & catholic protection potential
10. Routine daily checking of instruments (where controllers and critical indicators are not
involved) and analyzers.
11. Routine Checking / surveillance of machines, Following jobs are included (Routine
Checking / surveillance) in this permit
• Take Temperature
• Take Vibration.
• Take measurement of equipment by maintenance person.

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• Temperature monitoring through Infra-Red Gun


12. Audit performed by Maintenance, I&E (Motor physical inspection Audit, Motor
Temperature measurement Audit, Lighting fixtures / cables / cable tray Audit, Earthing
Audit), & Technical etc.

4.6 Retention of Permits


1. HARD and WHITE copies of Work Permits to be retained by respective Production and
Maintenance interface for ONE MONTH.
2. For confined space entry, work permit to be retained for a year by respective Production
and Maintenance interface
3. In case of an incident, the scanned image of permit shall be attached to the incident report
and its HARD/WHITE copies are to be retained by the respective Departments or Safety
Section until investigation report is issued.

4.7 Entering Operating Units


1. When it is necessary to enter an operating unit to reach the permit issuing area, the
individual is required to go directly to the permit issuing area.

2. Anyone requiring entry to a unit or area when a Work Permit is not required may do so
by first acquiring the MSO / Shift In-Charge permission.

3. The above rule (Entering Operating Units) is not applicable for entering Control Rooms
and PM&S. This will also not be applicable during Plant Turnaround or major Shutdown.

4. The contractors and their work force are not allowed to enter the operating areas unless
required through Work Permits or work orders. If a contractor is required to enter in
operating areas for other than Work Permit/work order related jobs, he shall also follow
the above rules.

Note:
• Additional entry protocol set in Unit Management Manual to be abided.
• Roads between two operating units are exempted from entering operating units’ protocol.
(Marked diagram attached later).

4.8 Permit & Job Preparations in Night Shift for Execution in


Day Shift
To reduce the workload, a practice to be followed for preparation of permits by night shift
operations team for the next day morning shift. This preparation may include job preparation
i.e., equipment isolations, performing LOTOTO, scaffolding errection for job etc. or permit
preparations i.e., developing the permit without assigning date and signing it. This protocol
needs to be practiced by operations team for workload management.

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4.9 Exceptions
A Work Permit is not required for i.e., Housekeeping audit (without photography), MSA, PSSR,
PSM audit , Work permit audit, Safety Equipment’s audit (except Fire Hydrant Hose test) &
Environment survey, Ambient air monitoring. However, for all these activities, individual has to
inform MSO / SIC.

4.10 Unit Entry / Exit Protocol


To enter any operating area, individual need to take permission from area owner (SIC) before
going to site. Entry register is placed on respect DCS boards where entry must be recorded, and
card will be issued to enter the operating area.

4.11 Blind Tags


• Numbered tags must be used to identify blinds that are installed. Blind tags should be secured
with flange bolt or other suitable means in such a way that it could not be removed by
unauthorized personnel to avoid misplacing of tag.

• Blind installation on a vessel’s or exchanger (Shell & tube side will be considered two separate
vessels) immediate connected flanges (vessel nozzle flanges only) with approval of shift in-
charge. All other flanges will be dealt in separate individual permits. Please see below picture
for clarity.

• All tags must be removed / checked off on the blind tags check list before commissioning the
equipment.

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Document No.: HSE/ WP /SOP-SAF-08/ Level-III / 01


Date Prepared: May 2014
Revision due: May 2017
Orig. Prepared by: AH/ FH
BLIND TAG LIST
Job Description:

Equipment: ________________________________________________________________________________

Date: ____________________________________

S.# Tag Location Tag installed by Time Tag removed by Time Date

Sample Blind List

4.12 Inter-unit Isolation Protocol


1. Purpose of this procedure is to safeguard the worker and to ensure that any
line/equipment handed over for mechanical work is properly isolated, so that the job is
executed under the safest possible conditions.

2. This procedure is applicable to all interconnecting lines/equipment between different


operating units of the plant which need isolation at some other location/plant. The
procedure defines the responsibilities of different individuals for carrying out a job on
inter-connecting lines.

3. Conditions may, however, arise where this procedure will be required at some other
streams as well. Such lines may be treated as special cases and dealt with the same way as
the lines shown in the list.

4. For example, if work on EDC VCM MCC bus bar need to be done, then isolations are
conducted from UTY GSS and locks are applied in GSS breakers. In the same way, if job
needs to be executed on VCM line in PVC unit coming from EDC VCM bullets, then it
must be isolated and locked out from EDC VCM plant.

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a Procedure for Isolation of Inter-Unit Connecting Electrical


Breakers
This procedure defines the responsibilities of different individuals (Production) for proper lock
out / tag out of electrical breakers before a maintenance job is to be carried out:

1. Production SIC in whose area work is to be carried out will fill out and sign “REQUEST
FOR LOCKOUT / TAGOUT” (as shown in figure). He will send the request together
with the red lock to his counterpart at the other plant for isolation and lockout where
the electrical breakers are installed.

2. The receiving unit SIC at the other plant will get the required electrical breakers isolated
and locked out / tagged out as per procedure. The electrical breakers will be tagged with
the upper portion of the “REQUEST FOR LOCKOUT / TAGOUT CARD”. He and the
area engineer will sign the lower portion (verification tag) of the tag with time and date
and send it back to the originating SIC along with key of red lock installed at the electrical
breakers.

3. On receiving the verification tag, the originating


area SIC will ensure isolated system is de-energized
by operating the equipment from local switches or
unit specific MCCs. By ensuring this, he will initiate
the work permit after putting the red lock key in
the key box. Further, verification tag will be pasted
on SCD board in CCR.

4. The maintenance supervisor / lead person would


go to the breaker and personally install his
departmental lock on the electrical breakers, will
mention the number of locks on permit and will
place the key in department’s designated key box.

5. Upon completion of the job i.e., after work permit


has been returned by the maintenance,
maintenance supervisor will remove his lock from
the electrical breakers and operations SIC will sign
and send the “AUTHORIZATION TAG” to unlock
the electrical breakers along with the red lock key
to the interconnected unit.

6. Upon receiving the “AUTHORIZATION TAG”


from the originating SIC and the key to unlock the
electrical breakers, the area engineer on SIC permission of the isolation performing plant
will unlock the electrical breakers.

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7. This lock & key along with AUTHORIZATION TAG will be returned to requesting unit
by isolation performing unit.

8. Normal isolation tags on breakers will be installed as it is. This will be the additional tag
that to be installed on breaker in case of interconnecting job.

b Procedure for Isolation of Inter-Unit Connecting Process


Pipelines
1. Production SIC in whose area work is to be carried
out (originating SIC) will fill out and sign "REQUEST
FOR ISOLATION". (as shown in figure). He will send
the request with the white lock to his counterpart at
the other plant where isolation is needed.

2. The receiving SIC at the other plant will get the


required line isolated as per procedure. The isolation
valve/s will be chain locked and tagged with the upper
portion of the "REQUEST FOR ISOLATION" tag. If
there are several locks to be isolated, then separate
tag will be developed for all valves.

3. He and the area engineer will sign the counter slip


(VERIFICATION TAG) and send it back to the
originating SIC along with the key to the white lock
(s) installed at the isolating valves.

4. On receiving the verification tag, he will initiate the


Work Permit after putting the white lock key in the
key box. Further, verification tag will be pasted on
SCD board in CCR.

5. Upon completion of job i.e., after Work Permit has


been returned by the maintenance, the line can be
put in service. For this, the originating SIC will send the AUTHORIZATION TAG with
his signature and date along with key of the lock (s) to remove Isolation from the other
plant.

6. On receiving the AUTHORIZATION TAG from the originating SIC, the interconnecting
line will be put in service as per the Standard procedure for that stream.

7. This lock & key along with AUTHORIZATION TAG will be returned to requesting unit
by isolation performing unit.

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c Examples of Inter-connecting links at site

1. All import lines like VCM, Ethylene, Raw water, Hydrogen lines etc. within or outside the
Plant Boundaries up to production battery limits isolation valve
2. Whenever work is planned on inter-unit connecting lines across the production units like
VCM/ Caustic line etc.
3. Any instrument related job across UTY/PVC-II shared Engineering server and control
cabinets for UTY instrument signals,.
4. All 6.6KV breakers in sub-stations that need isolation from main GSS. For Rack in/Rack
out in GSS, this protocol must be followed.
5. PVC-III interconnected lines at Uty plant

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SECTION-5 ROLES & RESPONSIBILITIES IN PERMIT


WORKFLOW
5.1 Primary Authorized Person (Area Owner)
It is the primary responsibility of the Authorized Person issuing the permit to make sure that it
is safe to perform the work in the area, equipment, or vessel. The person issuing the permit has
the following specific responsibilities:

1. To inspect the work area and determine if conditions are satisfactory for the work to
proceed.
2. To make sure that each item on the permit is accurately filled out, after due verification.
3. To make sure that the Maintenance Person understands the requirements on the permit
and any unusual condition/s connected with the job.
4. The authorized person or his designate shall continue monitoring the work area
conditions and shall stop the work if unusual operating conditions arise which may affect
the safety of the personnel and/or equipment.
5. He will also ensure that the Maintenance Person wears necessary personal protective
equipment and takes proper precautions for safe execution of the job.
6. To pass on all the pertinent information about the work in progress to his reliever.
7. To inform the person/s and area/s this will be affected on account of the job to be done.
8. To ensure that any line/equipment handed over for maintenance work is properly isolated
/ locked. Interconnecting lines isolation between different operating units should also be
carried out if required.
9. To make sure that Electrical lockout / tag out / try out / test out procedure is followed
whenever a Maintenance / Electrical job is to be carried out on equipment which requires
Electrical isolation.

Note: Authorizing persons are the area owners in case of non-operating areas and SIC/MSOs
in case of operating areas. At EDC VCM plant, shift supervisors can also authorize/initiate work
permits along with SICs. Shift supervisors are not allowed to authorize permits including SCD,
LOTOTO, electrical live permit, hot permit, radiography & confined space permit. This protocol
is only valid for EDC VCM plant.

5.2 Principle Authorized Person (Maintenance Person)


Although the person issuing the Work Permit has primary responsibility, the Maintenance.
Person who receives the permit also has the following responsibilities:

1. To make sure that the authorizing person understands the location, nature, scope and
procedure of work to be performed.
2. To comply with the conditions stated on the permit.

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3. To use the proper tools and equipment for the job.


4. To wear necessary personal protective equipment for safe execution of the job.
5. To clearly display the work permit at the location while executing the job.
6. To follow safe work practices and procedures including Electrical or Valve lockout / tag
out procedure and Confined Space Entry Standard.
7. To notify the issuing authority of any change in condition or scope of the job or the
surrounding area, or any delay in starting work.
8. Housekeeping and cleanup of the area and equipment upon completion of work.
9. Notify issuing authority or designate upon completion or incompletion of work and
exchange the HARD copy of the Work Permit with the WHITE copy after signing and
getting operator's signatures on the WHITE copy. WHITE copies will be returned to the
maintenance supervisor.

Note: It is MANDATORY for the Initiator, Authorizing Person, and the Maintenance Person
to sign the work permit properly with the employee no. to ensure identification.

5.3 Responsibilities for Excavation Work Permit


It is imperative to ensure that during excavation, no underground piping, electrical cables,
cathodic protection, or grounding system will be encountered. In case the piping or electrical
cables are present, and excavation is still to be carried out, this should be in the knowledge of all
interfaces so that necessary safety measures are taken not to damage the piping or the cables
during excavation. Following interfaces are assigned the responsibility to check the presence of
underground piping/electrical cables.

1. Project Engineering Manager / Designate


He will ensure that updated/evergreen drawings for underground piping are available for the total
site. He should consult the relevant drawings for the presence of underground piping before
signing the permit. If needed, field visit should be carried out to mark the area. In case of doubt,
supervisor must be consulted before signing the permit.

2. Electrical Manager / Designate

• He will ensure that all drawings for underground electrical cables, cathodic protection or
grounding system are available and updated on evergreen basis. The drawings must be
consulted before signing the excavation permit.
• Area must be visited if needed and consultation with the supervisor should be carried out in
case of doubt. Electrical must confirm the location of the cables through cable locator before

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job execution. Cable locator to be used for walls as well. In case of unavailability of cable
locator, complete power of that room or area to be switched off.
Caution: Wrong information can jeopardize the safety of personnel and equipment and may
result in a serious safety incident.

5.4 Accountability

• All responsibilities for safe job execution and follow-up of safe work practices are laid with
the Permit Authorizer and Permit Acceptor.

• For any work permit procedure violation, near miss or incident, they will be accountable for
that, as it is prime responsibility of Permit authorizer/ Acceptor to satisfy the Process and
personnel safety conditions in area while performing field activities by any interface.

• It is Mandatory that all interfaces briefing about job scope and permit issuance should be done
at actual job location. The EPCL supervision (Operation and Maintenance interfaces) shall be
remained there for monitoring till work permit closure either job is complete or incomplete.

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SECTION-6 PERMIT ISSUANCE WORKFLOW

The following are the procedure, outlines & steps for obtaining Work Permit from authorized
Production employees:

1. The Maintenance Person informs the concerned Authorized Person (s) about the nature
of the job and how it must be done and requests the relevant Work Permit.

2. The Authorized Person (SIC) or his designated Skill Certified Post Operator inspects the
work area, prepares the equipment for the job and determines if conditions are
satisfactory for the work to proceed as follows:

3. If conditions surrounding the work area are satisfactory and no gas analysis is necessary,
the Authorized Person (SIC) then completes, authorize the permit & hand over to Area
operator.

4. If conditions surrounding the proposed work area are satisfactory, but a gas analysis is
necessary, the Authorized Person (SIC) will have the gas test done. Upon receipt of a
satisfactory gas test result, the Authorized Person (SIC) then completes, authorize the
permit & hand over to Area operator. Actual reading of explosivity shall be recorded on
the permit.

5. Area operator prepares the job and discuss hazard of job with maintenance person at
location. After discussion both individuals signed off permits and exchange copies. Hard
copy with maintenance person (on the location of the job) & Area operator sends white
copy to field office.

6. Job handover must be done in field location or platform where job is required to be done.
If condition surrounding the area is not satisfactory for work to proceed, the Authorized
Person (SIC) will inform the Maintenance Person, who will contact his supervisor for
further instructions.

7. It is the responsibility of the Authorized Person (SIC/SS) to brief the Maintenance Person
on any specific conditions existing in the area where the work is to be done, about which
he should be aware of so that he can perform his work in the safest possible manner and
under the safest possible conditions. The Maintenance Person should be made aware of
any specific fire hazards, possible contact with any chemicals or the possibility of being
exposed to toxic gases.

8. The Maintenance Person signs the permit as a token of his complete understanding of the
safety requirements to be observed by him and by all EPCL and Contractor employees
working with him and the steps will be taken in sequence to ensure safe completion of
the job.

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9. Hard copy displayed at job place until completion of job. Area operator, maintenance
technician & supervisors responsible (as per their role) for its validity & safe execution of
job.

10. The designated Post Operator places the original WHITE Copy on a clip board in the
field office where it remains for reference until the job is completed.

11. Maintenance people complete the job and handover hard copy to operator. Maintenance
person & Operator sign off both white & hard copies & hand over white copy to
maintenance person. Area operator sends hard copy to SS / SIC. This should be followed
even if job is left incomplete.

12. Maintenance person hands over all the white copies to his supervisor. White copies to be
retained for one month by the respective manager.

13. Hard copy in control to be retained for one month by the Operations Manager.

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6.1 Spare / Redundant Breakers / Cubicles

• All the spare/redundant breakers/cubicles will be locked by Production Department using red
locks. The red lock key will be retained by the Operations Manager.
• A tag will also be installed at the breakers on which date and reason for installation will also
be mentioned.
• The tag will be installed by the Shift In charge(s) and co-signed by the respective Managers
Usage of this cubicle/breaker will be subject to fulfilling the requirements of Management of
Change.

6.2 Maintenance of power-driven equipment in Workshops


• Lock out, tag out, try out & test out procedure must be followed for any maintenance job to
be carried out on a power-driven machine / equipment installed in Shops.

• Two locks will be installed for lock out. A yellow lock will be installed by the Shops supervisor
while a green lock will be installed by the Electrical technician. The key to yellow lock will be
retained by I&E Supervisor while the key to green lock shall be retained by the person involved
in maintenance of the equipment.

• Tags to be installed as per LOTOTOTO revised tagging regime. If switch unplugging of power-
driven equipment is fee sable it should be followed and switch to be tagged otherwise breaker
LOTOTOTO protocol mentioned above must be abided.

6.3 Person authorized to issue Work Permit

1. Cold Work Permits shall be authorized by the Shift In-charge.


2. For cold work involving safety critical equipment, only Shift In charge shall be responsible for
authorizing the Work Permit.
3. Hot Work Permits shall be initiated by Shift In charge and authorized by the MSO for
operating areas including CCR. However, for Non-Operating Area(s) hot work shall be
authorized by Area/ Building Owner.
4. Electrical Work Permits on de-energized circuits will be authorized by the Shift In-charge.
5. Work on high voltage circuits i.e. 6.6 KV or above should be authorized in accordance
with the LOTOTOTO procedure. Such jobs will be authorized only when requested by
Electrical Manager. The concerned SIC and the Electrical Engineer / Supervisor must
personally check that the correct breaker has been racked out, the system de-energized and
properly locked / tagged out.
6. Confined Space Entry Permit will be authorized by the Shift In charge.
7. Excavation and Civil Work Permits will be Co-signed by Project Engineering Manager /
Electrical Manager or their designates and authorized by the Shift In-charge.
8. Vehicle Entry Permits will be authorized by the Shift In-charge.

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9. Lifting over Process Equipment Permit will be authorized by the Shift In Charge. In
case, a potential for process incident is present, the permit will be completely filled (defining
the path load and where boom will swing) and co-signed by the Maintenance Supervisor.
10. Radiography Work Permits will be initiated by Inspection Engineer/ Supervisor and
authorized the Shift In-charge.
11. It is MANDATORY to sign the work permit properly and employee no. should be clearly
mentioned.

6.4 Work on energized equipment:

1. Work Permit for work on energized equipment with voltage below 600 V, is to be authorized
by SIC only and cosigned by Electrical Engineer / Manager.
2. Work on energized equipment above 6.6 KV should be avoided as much as possible.
However, if the job is unavoidable, Work Permit will be requested by Electrical Manager after
carrying out a JSA. Furthermore, the presence of Electrical Engineer/Supervisor on such a job
is MANDATORY.
3. Work Permit for work on energized equipment with voltage above 6.6 KV will be authorized
by SIC and cosigned by Electrical Manager. Presence of Electrical Engineer/Supervisor is
MANDATORY during the execution of the job.
Note: All jobs on live circuit above 6.6 KVA should be informed to MSO before issuing a permit.

6.5 Work on Safety Critical devices / instrumentation /


equipment:

1. For Safety Critical devices / instrumentation / equipment, Instrument Engineer / Supervisor


shall sign the I&E related part of the Work Permit and the permit is then approved /
authorized by the Shift In charge only. He shall obtain permission of the concerned
Operations Manager.
2. Follow specific procedures / guidelines as given in Safety Critical Devices Manual and relevant
I&E procedures while bypassing, dummy checkup or working on any device / security loop.
3. Permit for changing the set point of Safety Critical devices will be issued only if request for
changing the set point initiated, has been reviewed by the area Operations Manager and
Process Engineering Manager and approved by the Chairman Sub HSE Process.
4. Request for change in shutdown logic will require further review by the Chairman Sub HSE
I&E and approval by MHSE Chairman in addition to reviews mentioned in the clause above.

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6.6 Work on Non-Safety Critical devices / instrumentation


/equipment:
1. In case of job on non-safety critical devices / instrumentation / equipment, Shift in-charge can
authorize the Work Permit.
2. Permit for Instrument set-point change of non-safety critical device is to be issued only if an
approved Set Point Change Request form is available. The form must be reviewed by Process
Engineering Manager and approved by the area Manager.
3. Work on energized devices / instrumentation / equipment:
a. All Instrument Work Permits involving energized electrical circuits will be authorized
by the Shift In charge only.
b. Work Permit for any job on energized circuit exceeding 48V shall be authorized by
Shift in charge and cosigned by Instrument Engineer.

6.7 Jobs Authorizations on Single Permit


1. LV/MV breakers monitoring - LV/MV breakers monitoring in substations cane be
authorized on single permit for same substation or MCC. However different substations will
require a separate permit for monitoring.

2. PM of ACs in a same building – PM of all AC's installed in a single building can be


authorized on a single permit, whereas for CM jobs, separate permits to be issued for all ACs

3. PH analyzers PM – A single permit to be authorized for pH analyzers PM of a specific area.


PM includes physical checks and flow adjustments can only be authorized on a single permit
for an area. Any other physical job required at an analyzer will be taken up on separate permit.

4. Machine's surveillance - Single Permit can be issued for all machine's surveillance (without
any physical job) for each unit of ROP (CA, UTY/Power & PVC-I/II). Each unit to follow below
identified operating posts for single permit receiving, while maintenance person will inform
the other operating post AAE on ROP before initiating surveillance. Following posts Area
Engineers are authorized to handle above permit:
a. PVC-1/2 - Front End AAE of 1 & 2.
b. UTY/PP - Area-1 AAE
c. CA - Post C AAE
d. This change is not applicable on EDC/VCM unit.

5. DCS Screens Monitoring/PM - Single permit can be authorized plant wise for handling
DCS faulty monitors/screens replacement or for PMs of these screens.

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6. Insulation & Cladding on Same line - Single permit can be authorized for insulation and
cladding installation at multiple locations on same service line in multiple areas.

7. End blinds Installation – Installation of end blinds and caps on lines/drains can be
authorized on single permit for a specific area. However, a P&ID must be marked showing all
end points that will be blinded and this P&ID must be attached with the permit.

8. Piping layout - Single permit to be issued area wise for piping layout without any rigging
activity. Manual pipe laying can be authorized on single permit.

9. DPT on Same Hot Permit - DPT can be done on the same hot permit on which welding
is being performed on a specific point. Responsible of the job would be maintenance team.

6.8 Protocol for Off Hours Work Permit Issuance


On weekends/off hours, for any unplanned critical job, after informing MSO, following Production
shift in charges will authorize the work permits after detailed job briefing, field visit and
understanding of hazards associated with jobs. Respective unit Shift In-charge shall assign his Area
Engineer to monitor the area conditions during job execution.

1. PVC Shift In-charge Areas:


New chemical warehouse, new general warehouse and new workshop, Old warehouse and
workshop, Old training facilities, Laboratories, Admin building, Canteen, SRM Building, Hussain
Dawood building, Old/ New entrance facility, Off-spec yard, and Old china town building.
2. UTY/CCPP Shift In-charge Areas:
New CCR, Fire station, KESC transformer yard (11KV room) and breaker room (PVC I/II SS &
GSS), SSGC room (old and new facility), Old MCC, MLT room, new Entrance Facility, new field
office, New Scrap yard, Clinic/ Fire truck room, Entrance Facility, Logistic Building, Boundary
Wall, Admin Roads, Main Gate, Security Check posts and all other buildings.

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SECTION-7 JOBS IN NON-OPERATING AREA

Following are the building owners at manufacturing Site:

Building Department
CCR Building, 11KV Room, GSS, PVC I/II SS & SSGC Room, VCM Field
Office - Pantry, Toilet and vicinity, Fire Station Storeroom, Fire Truck UTY/CCPP Ops.
and Station, E-Pond Area
PVC I/ II Field Offices & PVC I rack room PVC Ops.
Main Laboratory/ HVAC Room Lab
PVC III CCR, Field office, Sub-station PVC-III
CA workstation, CA Substation, Salt Yard CA
Warehouse (New/Old/ Chemical), Scrap Yard, Open Yard (MWH South
Warehouse
side), PVC III chemical warehouse
I&E offices, I&E Workshop & HVAC Technician Area I&E
Maintenance
Maintenance Workshop including Associated Workshops
Workshop
Contractors Sheds & Adjacent Area Planning
SRM Building Ground Floor, Project Equipment Lay down area Project
SRM Building First Floor, Training Miniature Facility & Skill Lab (Old
Training
Training facility)
Logistics Building, Weigh Bridge, PM&S, Drivers Washroom, Off-spec
Logistics/ PM&S
yard & Caustic Tanker Loading Area East & North Parking, PVC III PM&S
Admin Buildings/ Offices, Canteen (EPCL & Contractor), Non-Operating
Areas, New/ Old China Town, Hussain Dawood Building, Driver Rest
Room, Driver Canteen/ Prayer Area, Old/ New Entrance Facility, Old/
Admin
New Car Parking Area, All Roads except within operating areas, Admin
Prayer Area, Clinic, Contractor Washroom, Duck Pond, Plant Boundary
Wall/ Gates & Check posts

7.1 NON-OPERATING Areas Work Permits rule

• On working day, for any maintenance related activity, permit shall be authorized by Area
owner or his designate.

• There are certain jobs in these non-operating areas which are conducted by Contractor
employees and supervised directly by area owner. In such cases, relevant Work Permit will
be approved as Shift in-charge by area owner authorized person.

• Moreover, any work permit qualified person of respective area can act as the Maintenance
Person & Area operator. Individuals signing the permit will be responsible for safe execution
of the job.

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SECTION-8 PERMIT AREA ROAD MAP

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SECTION-9 TYPES OF WORK PERMITS


9.1 Cold Work Permit (Green Card)

3. A Cold Work Permit must be obtained for all types of work not covered by any other specific
Work Permit.

a. Collection of samples.
b. Preventive maintenance inspections.
c. Checking of instruments (Local Pressure/Temperature gauges, Visual inspection of JBs,
Control valves etc.)
d. Routine checking of machines.
e. Inspection of grounding clamps, cables and cathodic protection potentials.
f. Greasing of machines.
g. Rack-in/Rack out 6.6 KV VCB or higher in Switch gear by electrical technician.

4. All types of Maintenance / Project work (not covered by other specific Work Permits) and a
few electrical jobs in the Plant areas require this permit. This permit is designed to provide
close cooperation between Maintenance / I&E / other interfaces and Operations personnel
and to establish work conditions and procedures to ensure safe work performance.

5. Cold Work Permits shall be authorized by Shift In-charge. For the jobs requiring lock out /
tag out of the equipment, Electrical / Valve lock out, tag out, try out and test out procedure
must be followed.

1. Work on Safety Critical devices / equipment:

1. For Safety Critical devices / equipment, the permit will be approved / authorized by the Shift
In charge. He shall obtain permission of the concerned Operations Manager. The EPCL
Maintenance Engineer / Supervisor shall cosign Work Permit.
2. If required, during off-hours EPCL Maintenance Shift Engineer / Supervisor shall come to the
plant site for signing the work permit of Safety Critical Devices. (For PSV or Over Speed Trip
only).
3. Follow specific procedures / guidelines as given in Safety Critical Devices Manual and relevant
Maintenance procedures while bypassing, dummy checkup or working on safety critical
device.
4. Permit for changing the set point of Safety Critical devices will be issued only if request for
changing the set point is initiated by any Engineer / Supervisor has been reviewed by the area
operations Manager / Process Engineering Manager and approved by the Chairman Sub HSE
Process.

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9.2 Hot Work Permit (Red Card)


A Hot Work Permit is required for any job where the heat generated is of sufficient magnitude
and intensity to cause ignition of any flammable liquids, gases or any other material.

As approved by MHSE following approving protocol to be followed for Operating Area including
CCR;

• Non-Classified Area
Hot Work Permit Initiate by: SIC Authorized By: MSO
Hot Job Checklist Not Required

• Classified Area
Hot Work Permit Initiate by: SIC Authorized By: MSO
Hot Job Checklist Initiate by: SIC Authorized By: MSO

• Protocol for Planned Jobs - Approval with: Manager or MSO


• Unplanned Jobs - Approval with: GM Production

For Non- Operating Area(s) hot work permit shall be authorized by Area Owner.
Hot permit must be obtained for tightening of flange by Hammering in classified area. However,
cold permit is required if brass / rubber hammer is used for hammering.

Hot work so defined shall include:

1. Oxyacetylene heating, welding and cutting, electrical welding, soldering, brazing, hot riveting,
grinding and grit blasting, electric tools and any other spark producing operation such as digital
cameras, photographic flash bulbs, strobe light, holiday inspection, other electrical / electronic
equipment which are not vapor proof /intrinsically safe, work on live electrical equipment or
any similar operations.
2. Making fires for insulation etc. and cutting of lines, tunings, metallic supports using hacksaw is
also covered by this Work Permit.
3. Before issuing the hot Work Permit it is imperative to get the gas testing done by a qualified
gas tester. The actual reading is to be recorded on the permit.
4. It must be ensured that the explosivity meter is healthy and the reading obtained is correct.
LEL monitoring to be maintained on the back side of work permit card copy on one hourly
basis by respective operating unit.
Note: Hot work permit will only be issued if LEL is 0%.

5. This permit must be issued for all hot jobs at the Plant site except in Mechanical Shacks, HPWJ
areas, Shops, Motor Pool and Project Fabrication sites outside Operating Units boundary
limits (such as north side of workshop near the road), and exchanger cleaning yard (east side
of CCR).

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1. Necessary Precautions

1. The job has been reviewed with all the interfaces involved. Also, estimate the job area which
must be cordoned off.

2. All gas flanges, valve glands & bleeder openings have been checked for explosivity in the job
area, if leakage found, get it attended first. Check explosivity all around the flanges.

3. In case leakage cannot be removed then cover the leaking point properly with fire resistant
cloth & provide steam blanketing.

4. For hot job at grade level, all drains & manholes within 10 ft. of the workplace are adequately
covered.

5. For hot job at heights, all drains & manholes within 20ft. of the workplace are adequately
covered. The area may be increased depending upon the wind direction.

6. All loose flammable or combustible material are removed from the area (e.g., gloves, coarse
cloth, paint, polythene, or WD-40 cans).

7. Fire extinguisher or Water hose available at hot job location.

8. Enclosure (Canopy) has been made for the job execution on job location. Canopy should be
sufficient to retain all the welding spatters falling on gas flanges, valves, fittings or instrument
cable trays.

9. Canopy enclosure arrangements shall be inspected and certified by Shift In-charge/MSO on


Hot job checklist. Welding machine/cables are in good condition & welding earth cable is
installed closest to the job & properly clamped. Also, check for external earth wire.

10. Gas cylinder for welding is located at least 20 ft. away from the hot job point to avoid any
sparks falling on it. Also, gas leads from cylinder to torch are in good condition.

11. Scaffolding is properly installed & wooden planks are firmly placed, Planks tied up with rope,
scaffolding certified, wetted with water & safe for the job. If planks are not wetted, then
maintenance supervisor should protect them with fire resistant cloth or metal sheet.

12. Scaffolding is properly installed & wooden planks are firmly placed, Planks tied up with rope,
scaffolding certified, wetted with water & safe for the job. If planks are not wetted, then
maintenance supervisor should protect them with fire resistant cloth or metal sheet.

13. After job completion, keep the area under surveillance for 30 minutes to avoid potential fires.

14. Floor clean of combustibles within 35 ft. of work. Good housekeeping is the key to fire
prevention.

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15. For drilling, Nailing & other insertion activities on walls, Hot Work Permit to be cosigned by
Electrical Supervisor/ Engineer after verification of sub surface electrical cables.

2. Exemption
All smoking stations are work permit free area. Moreover, no permit is required for Photography
in the following.

Control
Admin SRM
Room Field Offices Offsite Prayer Areas
Building Building
Building

Warehouse Old
Operations Weigh
PM&S (New/Old/ Scrap Yard Inspection
Pantry Bridge
Chemical) Office
All Roads Old/ New Canteen
except within Car Parking
operating
Entrance (EPCL & Clinic Fire Station
Area
areas Facility Contractor)

Civil Skill Lab (old


Logistics Off spec Drivers Wash Contractors
Contactors Training
Building yard Room Sheds
Shed facility)
Old china town I&E Work
Small Workshop & & Storage shed Shop & HVAC
Workshops All under Technician
warehouse Area

However, prior proper approval must be taken from Area Owner.

3. Use of Unclassified Equipment in Classified area for repairs work.

Use of unclassified Equipment in classified area for repairs work can only be authorized by MHSE
chairman with following precautions:

1. Monitor explosivity all around up to 100 feet vicinity of location of Equipment / repair area
by operation and rectify all explosivity sources if found.
2. If any explosivity readings are obtained, then work cannot begin or continue until the source
of vapor is found and suitably mitigated such that the concentration is maintained below 3%
of the Lower Flammable / Explosive Limit. For technical assistance regarding combustible gas
meters, contact Safety Section.
3. Continue monitor explosivity of above area with interval of one hour by OPS.
4. Follow site protocol of authorization for electrical drill / grinder.
5. Take hot work permit for the job and follow all requirements of hot work Permit.
6. All non-IS equipment entry in classified areas are not allowed until hot work permit has been
authorized and taken over by the work execution party.

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7. All non-IS equipment must remain inside the canopy during the hot job and LEL monitoring
must be done accordingly in the nearby vicinity as per hot job protocol.
8. During hot jobs inside the canopy, adequate protection should be provided to Non-IS
receptacles. All non-IS equipment should be removed from the area before the closure of
work permit.
9. Unattended / not in use non-IS equipment presence in classified area will be considered as a
violation of site HSE SOP
10. A hot permit must be taken whenever there is a requirement to open PLC panel door
(including BMS) and similar non-classified JBs/panels door in classified area. Following protocol
to be followed for hot permits of such jobs:
a. Hot permits for JBs/PLCs door opening can be authorized by SIC. MSO must be
informed by SIC related to job.
b. Single permit can be issued for similar non-classified JBs door opening in a same
operating area (Not complete unit just in same area such as EDC VCM A-100).
c. Fire extinguisher to be placed on location.
d. LEL monitoring to be done on hot permit.
e. Hot permit to be closed once the activity on the JB is completed and its door is closed.
11. Separate instrument or cold permit will be taken for any job on non-classified JBs or PLCs
other than hot permit.

4. Hot Tap or Hot Work on Operating Equipment


Hot tapping on any operating equipment or lines (specifically for equipment which has not been
freed of process material) is not allowed until prior approval from MHSE chairman has not been
taken.
A detailed procedure for hot tapping is to be approved from Sub-HSE (M) by maintenance
department. No work permit will be issued for any hot tap job unless there is a Sub-HSE (M)
approved procedure provided to production section.

The following instructions should strictly be followed before issuing such a Work Permit:
1. For all hot jobs in Plant operating area, an approved Job plan with JSA from Maintenance is
required and to be finally reviewed by MSO or his designate before field execution.
2. Hot job checklist is mandatory to be filled for hot jobs specifically welding, cutting, grinding
and heating with torches. It will be initiated by Area Engineer after ensuring necessary checks
on hot job arrangements like canopy enclosure etc., verified by Shift In-charge and finally
authorized by MSO on basis of hazardous area classified.
3. Ensure that there is a continuous and sufficient flow of liquids or gas in the line to be hot
tapped so that the heat of welding is adequately dissipated.
4. Operating pressure and temperature shall be within the allowable rating for the hot tapping
equipment.
5. Hot tapping or hot work should not be allowed on known thin or preened areas or areas
where temporary repairs have previously been made. Prior to any such job, thickness
measurement must be carried out and certified by inspection.
6. Hot taps or welding should be avoided on lines or vessels having internal cement, cast able
lining or rubber lining.

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7. Hot work on low temperature equipment (below 50°F) should be very critically reviewed
with inspection since brittle fracture can occur on some steels at low temperature.
8. Hot tapping is not permitted on a tank or vessel shell unless the liquid level is at least 6 feet
above the connection to be made.
9. All persons involved in hot tapping or hot works on operating equipment must be equipped
with necessary eye, face, hand, and body personnel protective equipment depending on
physical conditions. Live air mask must be available for ready use for each personnel involved
in carrying out the job (if required).

5. HSE Waiver Protocol for Hot jobs:

1. Under no circumstances hot work will be allowed on lines or equipment containing the
following, but not limited to, except with the prior MHSE Chairman approval.
a Vinyl chloride monomer, Ethylene di chloride, Hydrogen and all other highly flammable
process chemicals.
b Oxygen
c Compressed air, where the air has been compressed by oil lubricated compressor
d Chemicals, susceptible to decomposition due to heating
e Caustic soda solution or Sulphuric acid
f Flammable / combustible mixtures.
g Alloy or any material which requires stress relieving which cannot be done when the line
or equipment is pressurized.
h Hot work on lines or equipment where metallurgical changes can occur in heat affected
zone. Carbon for example, is changed metallurgical at high temperature in the presence
of hydrogen, caustic etc. Inspection must always be consulted in all such cases.
2. Waiver for hot jobs will only be granted to Area Owners (as Production for operating areas)
as they have better understanding to their workplace hazards related to hot jobs and
emergency actions for unforeseen situations.
3. For waivers to specified hot jobs, following hot job/ Canopy checklist protocol will be utilized.

6. Fire Watcher(s) & their Role Statement

1. Fire watcher is required whenever hot work is performed in locations where anything greater
than a minor fire might develop.
2. Fire watcher to be deputed by Maintenance Workgroup / Job Executor for S/D jobs &
Production for Routine Jobs.
3. Nominated Fire Watcher have to stay at his job location all the time during the course of job
4. Fire watchers shall have fire extinguishing equipment readily available and be trained in its use.
5. They shall be familiar with means of communication in case of an uncontrolled fire.
6. They shall watch for fires in all exposed areas, try to extinguish them only when obviously
within the capacity of the equipment available, or otherwise communicate the emergency.

Note: Fire Watcher is required ONLY for hot work where there is visible flame i.e. Smoke,
Smoldering, Welding Flame, Spark, Hot spatter, Red Hot metal etc. Fire watch is not required
for PVC welding with hot gun.

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7. They shall maintain the requirements stated on the work permit and keep flammable materials
from ignition sources.
8. Fire watchers have the authority to stop work in case of an unsafe condition.
9. A fire watch shall be maintained for at least a half hour after completion of hot work to detect
and extinguish possible smoldering fires.
10. TAs can be deputed as Fire Watcher.

7. Protocol for Photography

• For photography in Operating area either classified or non-classified, hot permit must be
taken authorized by SIC. MSO must be informed while issuing & authorizing hot permit for
photography by SIC.
• For IS camera in classified and non-classified area, cold permit will be issued.
• In non-operating areas, no permit is required for photography, but formal
approval/permission of area owner must be taken for this.

8. Non-Exhaustive/Special Guidelines for Hot Jobs (Do’s & Don’ts)

1. Do’s

• Mark the blind or line cut points on P&ID.


• Ensure positive isolation of the pipeline and put do not operate tag on each valve.
• Drain, purge & Flush the pipeline thoroughly and Valve Lock-out-Tag-out procedure
except new piping.
• Ensure Lab Sampling with vacuum pump from line ambient and Flushing water for
• Hydrocarbon Nil.
• Identify specific hazards by making a field visit.
• Cover the chemical Sewer / manholes/ drain channel with fire blankets near or under hot
work area.
• Ensure water hose is installed at hot job location and hose air removed.
• Ensure non-metallic wooden planks adequately covered with fire blanket.
• Mention all control measures in risk assessment or job safety analysis and enclosed it with
work permit.
• Ensure Portable power supply DB, receptacles, welding plants, grading machines and other
powered devices are Electrical certified.
• Ensure Intrinsically Safe Electrical power supply and accessories are being used in
Classified Areas.
• Ensure Grinder Checklist has filed by relevant Engineer / GL.
• Communicate safety control measures to all the personnel involved.
• Ensure Hot job Approval taken for planned and unplanned jobs as per site HSE protocol
from relevant GL / GM.
• Ensure Hot job approval for Classified and Non-Classified Areas taken as per site HSE
Permit to work protocol.

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• Ensure LEL meter is healthy and calibrated and Area Assistant Engineer name present in
authorized gas test list of Unit.
• Check the LEL level before begin the hot work.
• Ensure Hot job enclosures / canopy are completed as per hot job canopy checklist.
• Ensure Hot job canopy checklist has initiated by Relevant Area Assistant Engineer after
physical visit to hot job location,
• Ensure Hot job canopy checklist has been verified by Relevant Shift In Charge (SIC) by
physical visit to hot job location.
• Ensure Hot job canopy checklist has been verified by Manager Site Operations MSO by
physical visit to hot job location.
• Ensure Hot job work permit initiated by SIC and authorized by MSO after above checks
verifications.
• Ensure training certified fire watcher available for designated hot job.
• Ensure LEL monitoring being done as per defined frequency and logged at work-permit
hard copy.
• Provide appropriate access, egress, and platform at all elevation.
• Use certified electrical equipment and ensure its earthing.
• Make a hot work booth, keep fire water and extinguisher at place.
• Cover all the hydrocarbon line passes through nearby area with fire blanket.
• Cordon off the area, install warning tag and warn the people.
• Always hook lanyard to fixed supports, platform railings, or lifelines.
• Use fall protection equipment wherever necessary.
• Provide scaffold for work at height.
• Secured all tools while working at elevated platform.
• In the event of fire, evacuate the area immediately and assemble at assembly point as per
Site ERP protocol.
• Ensure Fire watch man must stay at hot job location for 30min after job completion.

2. Don’ts

• Do not violate the safety conditions mentioned in hot work permit.


• Do not start the hot work before testing the LEL level (gas test).
• Do not perform do the welding and cutting on unidentified pipeline.
• Do not carry out any maintenance work such as strainer cleaning or sampling of
hydrocarbon near hot work.
• Do not carry out spark test by electrode on the associated pipeline or workpiece.
• Do not use pipeline or equipment or vessels as means of approach to work location.
• Do not connect the return lead of welding machine to the charged hydrocarbon pipeline
or scaffolding.
• Do not carry out the grinding and welding outside the welding booth.
• Do not left the site without switching off the welding machine and other equipment.
• Do not violate with compliance of Special PPE marked for hot job on work permit.
• Don’t’ Start hot job again if stopped due to change in Area conditions / process
• requirements (local hydrocarbon draining /venting as per plant needs)

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• Don’t start hot jobs if major changes done in canopy as per piping adjustment
• Do not throw any material from height, use rope to transport the equipment.

9.3 Electrical Work Permit (Pink Card)


1. This permit must be obtained before any work is performed on any electrical equipment
system, including motors and system of grounding. This excludes greasing and / or visual
inspection of motors, which will require a cold Work Permit.
2. Before issuing a Work Permit, it must be ascertained that whether the work will be carried
out on energized or de-energized equipment. Clarification to be sought if understanding is
not clear.
3. Before issuing a Work Permit for work on electrical equipment, the electrical power source
shall be turned off or disconnected strictly in accordance with the lock-out, tag out, try out
and test out procedure.
4. The SIC must personally check and confirm that the correct power source / breaker has been
turned off / disconnected, locked and properly tagged.
5. In case hot work is to be performed with the electrical work, an appropriate hot Work
Permit must be obtained in addition to the electrical Work Permit.
6. For electrical work carried out on equipment cubical Breaker inside MCCs, LT / MV
switchgears will be issued in consultation with EPCL Electrical Supervisor / Engineer keeping
in view Work in Proximity of live circuits.
7. Tagging of motors can be done during running / energized condition in presence of permanent
electrician.
8. For electrical work carried out in Electrical Shop other than on live electrical circuits, no
Work Permit is required.
9. Electrical Work Permits on de-energized circuits will be authorized by the Shift In charge.
10. Work on high voltage circuits i.e. 600V or above should be authorized in accordance with
the procedure. Such jobs will be authorized only when requested by Electrical Manager. The
concerned SIC / SS and the Electrical Engineer / Supervisor must personally check that the
correct breaker has been racked out, the system de energized and properly locked / tagged
out/ test out/ try out.
1. Work on energized equipment:
1. Work Permit for work on energized equipment with voltage below 600 V, is to be authorized
by SIC and cosigned by Manager Electrical / Electrical Engineer.

2. Work on energized equipment above 600 V should be avoided as much as possible. However,
if the job is unavoidable, Work Permit will be requested by Electrical Manager after carrying
out a JSA. Furthermore, the presence of Electrical Manager on such a job is MANDATORY.

3. Work Permit for work on energized equipment with voltage above 600 V will be authorized
by SIC and cosigned by Electrical Manager. Presence of Electrical Manager is MANDATORY
during the execution of the job.

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2. Work on Safety Critical devices / equipment:


1. For Safety Critical devices / equipment, the Instrument or Electrical Engineer / Supervisor
shall fill and cosign the related part of the Work Permit if Safety Critical Devices are MOVs,
or XSVs and the permit is then approved / authorized by the Shift In-charge. He shall obtain
permission of the concerned Operations Manager.
2. During off-hours / call-outs, the Electrical area Engineer / Supervisor shall come to the plant
site for filling and signing the work permit if Safety Critical Devices are MOVs, or XSVs.
3. Follow specific procedures / guidelines as given in Safety Critical Devices Manual and relevant
I&E procedures while bypassing, dummy checkup or working on any device / security loop.

a. Permit for changing the set point of Safety Critical devices will be issued only if request
for changing the set point initiated by any Engineer / Supervisor has been reviewed by the
area operations Manager / Process Engineering Manager and approved by the Chairman
Sub HSE Process.
b. Request for change in shutdown logic will require further review by the Chairman Sub
HSE I&E and approval by Manufacturing HSE Chairman in addition to reviews mentioned
in the clause above.

3. Working in Proximity of live circuits:


1. Proximity work is any electrical work sufficiently close to exposed and unguarded energized
conductors such that it is not the intent to touch the energized conductor but there is a
possibility of inadvertent contact.
2. For all such work, precautions taken and permit issued are to be similar as that for energized
circuit. The proximity limits for qualified electricians for different voltage levels are:
a. Less than or equal to 400 volts 03 inches
b. Greater than 400 volts up to 6.6 kV 1 foot
c. No work is allowed in close proximity of exposed, unguarded 11KV circuit.

4. Standby Person for Electrical jobs:


• On assessment of all risks involved in undertaking work associated with either lives
(energized) or de-energized equipment must consider all factors which may have the potential
to cause injury or damage, If this potential exists or any work in close proximity to live
electrical equipment.
• EPCL Electrical Engineer / Supervisor will depute a standby electrical person for precautionary
measures.
5. Employees on duty as Standby Person:

Where a person, equipment or mobile plant may inadvertently contact live electrical equipment,
such as bare or overhead wires, a standby person must be posted. The standby person’s duty is
as follows:

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1. Know / beware all risks involved in undertaking work associated with either lives (energized)
or de-energized equipment must consider all factors which may have the potential to cause
injury or damage and how to control.

2. Be familiar with the location of isolation breaker of affected circuit, exits, emergency siren,
and the contingency plan.

3. In case of emergency (electrical shock to person working on / near live circuit) the Electrical
standby person has an authority to put off / de-energize the upstream breaker for life saving.

4. Be physically capable of performing the duties assigned. The standby person is responsible for
stopping the job, and ensuring personnel’s exit from the job if Level-I, II Emergency siren is
sounded.

5. Use the walkie-talkie / intercom / whistle to call help in case of emergency before attempting
rescue when an emergency develops.

6. Can describe / execute the emergency rescue procedures (First Aid) for electrical shock
incidents, cardiopulmonary resuscitation (CPR) and (AED’s) automated external defibrillators
(if available).

7. Should be authorized by Electrical Manager, Electrical Manager should maintain up-to-date


records of individuals qualified as Electrical standby person. The list of authorized personnel
should be displayed in Electrical Manager Room & I&E workshop.

8. Each standby person should get refresher training at an interval of no more than three years
from the previous training.

9. Standby person should be:


a. Permanent employee.
b. Electrical Trade Apprentice/ TAE at least having six months experience at plant.
c. Qualified contract person only (authorized by Electrical Manager).
Note: All SBM’s should be trained and certified by HSE as per request. Approved list of SBM’s
to be maintained by HSE & Electrical Manager. Refresher training to be provided on yearly basis
for TA/TAE’s and on six monthly basis for contractor.

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9.4 Instrument Work Permit (Purple Card)


This permit must be obtained while carrying out jobs on the following:
1. DCS Systems
2. ESD, PLCs
3. Field Instrumentation
4. Analyzers and Scanners
5. Annunciator panels
6. Other instruments and control systems e.g. Anemometer, Recorders, Vibration Monitors

1. Work on Safety Critical devices / instrumentation / equipment:

1. For Safety Critical devices / instrumentation / equipment, the Instrument Engineer /


Supervisor shall fill and cosign the I&E related part of the Work Permit and the permit is
then approved /authorized by the Shift In-charge. He shall obtain permission of the
concerned Operations Manager.
2. During off-hours / call-outs, the Instrument area Engineer / Supervisor shall come to the
plant site for filling and signing the work permit.
3. Follow specific procedures / guidelines as given in Safety Critical Devices Manual and
relevant I&E procedures while bypassing, dummy checkup or working on any device /
security loop.
4. Permit for changing the set point of Safety Critical devices will be issued only if request
for changing the set point initiated by any Engineer / Supervisor has been reviewed by the
Area Manager / Process Engineering Manager and approved by the MHSE Chairman.
5. Request for change in shutdown logic will require further review by the Chairman Sub
HSE I&E and approval by Manufacturing HSE Chairman in addition to reviews mentioned
in the clause above.
2. Work on Non-SCD Instrumentation / Equipment:

1. In case of job on non-safety critical devices work permit will be authorized by the Shift
In-charge. Also, I&E Supervisor's designate (technician) is authorized to cosign the Work
Permit after filling the I&E related part of the Work Permit.
2. Permit for Instrument set-point change of non-safety critical device is to be issued only if
an approved Set Point Change Request form is available.
3. The form must be initiated by an Engineer/Supervisor reviewed by Process Engineering
Manager and approved by the Area Manager.
3. Work on energized devices / instrumentation / equipment:

1. For work on energized circuits less than 48V, the Work Permit shall be authorized by
Shift In-charge.
2. Work Permit for any job on energized circuit more than 48 ~ 220V shall be authorized
by Shift In-charge and cosigned by area Instrument Engineer.

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4. Other Guidelines

Following guidelines should be followed while carrying out an instrument related job:

1. The requirements of electrical lock out / tag out/ try out / test out must be fulfilled before
issuance of the Work Permit.
2. The permit to be issued / obtained after necessary discussion / understanding of
instrumentation being worked upon.
3. Ensure all interfaces have gone through the laid down procedures and agree on necessary
precautions to be taken throughout the activity so as to prevent an unsafe situation /
safety incident. In case of unavailability of procedures / doubt, consult area Manager.
4. In case hot work is to be performed, an appropriate Hot Work Permit must be obtained
in addition to the Instrument permit.
5. A separate electrical permit must be issued for electrical work on circuit breaker / leads
where required.
6. Ensure depressurizing / purging of the instruments is carried out safely while wearing
necessary PPE before issuing the permit.
7. In case the equipment is under pressure and hot, ensure adequate safety measures before
job authorization.
8. Ensure that the work area is free of any toxic gases and the area condition is sufficiently
open to allow for adequate ventilation.
9. A gas test is required for an Instrument Work Permit when using ignition source
equipment (e.g. multi meters) unless the area / equipment at which the work is performed
are free of flammable gas.
10. Permit for Instrument setting change of non-safety critical devices will be issued only if
the set point change request form initiated by any Engineer / Supervisor has been reviewed
by Process Engineering Manager and reviewed / approved by the area Manager.
11. For instrument work carried out in I & E workshop, no permit is required.
12. For effective communication, it is mandatory to inform and discuss in detail with DCS
Engineers for all instrument related jobs on instrument permit
13. For all Non-Safety Critical instruments which have no indication on DCS/PLCs, Cold work
permits protocol is utilized like Local PG’s/TG’s etc.
14. Boardman’s signature & P. no is MANDATORY on permit for work on field HMIs having
indication on DCS, control valve loops/trip logics/securities or interlocks of DCS ESD etc.

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9.5 Confined Space Entry Permit (Light Blue Card)

1. Non work permit required Confined Space Entry:

• A confined space that does not contain any hazards itself or exposed to atmospheric hazard
which can cause death or serious physical harm. Provided that safe means of entry / egress
from the confined space have been provided.
• Manager Operations, in consultation with HSE department, shall decide whether the confined
space is non-work permit required or not.
• Confined Space Entry permit can be exempted for excavated trenches of more than
4 feet with following arrangements:
a Free from Slush & water.
b Emergency exit route is free from tripping hazard (due to iron cage, demolished piles,
improper sloping etc.) and firm footing should be ensured at areas of entry / exit (access
and egress).
c Proper means of entry / exit (ramps, runway or ladder) are available at every 75-ft or as
recommended by EPCL safety interface. These should be provided at least at two
locations in a pit.
d Proper lighting arrangements should be provided at work area and points of entry /exit,
not less than 54-Lux.

2. Work Permit Required Confined Space Entry:


Any workspace that has a limited means of access or egress AND is not intended for regular
human occupancy AND has one or more of the following characteristics:

1. Contains or has the potential to contain a hazardous atmosphere.


2. Contains a material that has the potential for engulfing an entrant.
3. Has an internal configuration that might cause an entrant to be trapped or asphyxiated by
inwardly converging walls or by a floor that slopes downward and tapers to a smaller
cross section.
4. Contains any other recognized serious safety or health hazards for example;
a Process Vessels
b Boiler Feed Water Tanks
c Gas valve pit
d Wastewater pit
e GT’s Suction / Discharge plenum
f Internals of most Cooling Towers
g Effluent Treatment Tanks or Ponds
h Excavations (gas line) deeper than 4 feet
i Septic Tanks, Sewerage gutter
5. Entry requires special precautions, including a qualified and authorized Standby Person,
and a special authorization (Entry Permit)

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3. Confined Space Entry Work Permit Requirement

• A Confined Space Entry permit is to be obtained before any person enters a location defined
as Work Permit Required Confined Space Entry like tower, drum, reactor, tanks sewers, pits
or excavation more than 4 feet.
• This permit allows only the ‘entry’ into a process vessel or tank and not any work to be done
therein.
• If any work, other than visual inspection is to be performed in the process vessel or tank,
then the respective permit, Hot, Cold or Electrical must also be obtained.
• This permit must comply with all the requirements of the Work Permit Required Confined
Space Entry Standard.

4. Authorizations

A Confined Space Entry Permit must be authorized by the Shift In-charge before personnel can
enter a permit required confined space.

Note: The permit can be issued for one Operations shift only and cannot be extended.

5. Rules / Precautions

The following rules / procedures / precautions are to be observed whenever it is necessary for
any person (EPCL or Contractor Employee) to enter a confined space:

1. The Shift In-charge is fully responsible for the safety of the personnel inside the confined
space. However, compliance on the requirements of Confined Space Entry Standard and
Confined Space Entry Permit is mandatory for all interfaces.

2. The process or tank must be isolated and disconnected / blinded for all lines connected to it
keeping in view, the guidelines in Confined Space Entry Standard or a double block and bleed
arrangement to be provided if possible. Standard procedure for isolation/disconnection and
blinding requires:

a Give priority to complete disconnection


of all inlet/outlet lines at the closest
flange. However if it is not possible then
follow the requirements as describe in
section “Isolating Confined Spaces”.
b Complete disconnection of GLG and
other instruments if they are connected
to closed drain system / vent header/
utility header and drain / vent / utility line
is not blinded.

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c Blinding on the flange of inlet/outlet lines shall be the first choice.


d Standoff blind or slip in at the closest flange shall be the second or third choice.

3. Filled Blind / disconnect / double block & bleed check list along with simple sketch shall be
placed in the control room and on entry/ exit of confined space.

4. Process vessels, tanks and any portion of a line after the blind must be thoroughly washed,
purged and ventilated before the Confined Space Entry permit is issued.

5. In case where the vessel, tank or drums that contained used catalyst or any hazardous
chemicals are to be entered for cleaning etc. then an approved procedure must be followed.

6. In case vessels at the plant have nuclear level transmitters installed on them. The nuclear
transmitters must be isolated by qualified Inspection Technician/ Supervisor before allowing
entry into the vessel. Radiography Work Permit must be issued for isolation of the nuclear
transmitter.

7. Follow rescue plan of a vessel/ tank as specified in Confined Space Entry Standard. Arrange/
use all specified equipment for the personnel entering the confined space. Also, depute a
trained, knowledgeable, and certified standby person.

8. It will be the responsibility of production department to arrange a standby person at the entry
point of the confined space. The standby person should be fully knowledgeable on
requirements of his assignment, must fulfill all the requirements specified in Confined Space
Entry Standard and must be certified by HSE department.

9. Testing of walkie-talkie should be done to ensure proper signals are being transmitted/
received inside deep vessel before job execution.

10. Capacity/ adequacy of natural or forced ventilation against toxic vapor and fumes to be
calculated for each vessel and job situation and must be assured before personnel are allowed
to enter a confined space.

11. It should be recognized that certain metals, plastic and catalysts may present serious health
hazards when decomposed by burning or welding in an enclosed area. Coatings on some
welding rods can cause toxic fumes, such as fluorides, nitrogen oxides, etc. to be involved
when welding.

12. Also, argon welding causes reduction in oxygen contents in a vessel. High pressure breathing
air equipment or forced ventilation must be provided where any doubt about the purity of
the atmosphere in a confined space.

13. If a vessel had previously been kept under nitrogen blanket or purged with nitrogen or any
other inert gas, it should be thoroughly purged and ventilated with pressurized air and oxygen
tests made at three points in that vessel i.e. top, middle, and bottom.

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14. Entry into a vessel should not be allowed without appropriate PPE if oxygen content in that
vessel is less than 21% (vol.), the normal oxygen content in air.

15. Oxygen tests should be made at various points throughout the length/ breadth of a vessel.
Actual reading of oxygen and explosivity should be recorded on the permit with the signatures
of tester.

16. When adequate natural or forced ventilation cannot be provided in a vessel, compressed air
mask or Scott Air Pak set should be made available at the place of work if the Oxygen
concentration is 19.5% and the person entering the vessel should carry with him an oxygen
deficiency meter having an alarm set at 19.5% oxygen after which no entry is allowed unless
approved by MHSE Chairman and supplemented by a written/approved procedure.

17. A Confined Space Entry permit may be issued to one or more persons at a time and the name
of the persons deputed to standby at the entrance of the vessel should be clearly written on
the permit.

18. The permit shall be valid for one shift only. For any subsequent entry, a new entry permit
shall be issued. Blanket confined space entry permit cannot be given.

19. Ensure lockout, tag out, try out and test out procedure has been followed where required.
Also, ensure that rotary equipment and internal moving parts are mechanically locked and
secured where required.

20. Each person in the confined space must wear safety harness and lifeline at all times until
exempted by MHSE approval.

21. Lighting equipment (and wiring) inside the confined space must carry no more than 24 volts.
Low voltage lights and transformers are available with I&E.

22. Equipment requiring more than 24 volts to operate should be used only with an ELCB and
after special permission from MHSE Chairman. The transformer should be located outside
the confined space. Cables of lighting equipment should not create hindrance in the exit path.

23. For confined space entry, ELCB testing to be done on daily basis.

24. When welding or cutting inside a vessel is to be done, it is critical that adequate breathing air
must be provided to avoid gas pockets and fumes. When breathing air is deficient, a special
air supply must be used.

25. When welding or cutting is to be done inside a confined space, all cylinders and welding
machines should be left outside the confined space or vessel.

26. A hot work permit must be obtained and displayed at the work site while carrying out a hot
job. A fire extinguisher and a water hose should be available nearby. Hot work/ Canopy
checklist should be filled before starting the hot job inside the confined space.

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27. Marked P&ID signed off by Shift In charge with employee no. for each shift must be placed at
the point of entry.

28. Similarly, an Approved Rescue Plan must be placed at the point of entry.

29. Gas test results to be logged on the back side of work permit.

Note: Use of safety harness with lifeline is mandatory for vessel entry (until exempted by MHSE).

6. Exemption

1. Permanent open top structure containing equipment not in hydrocarbon service which are
required to be entered on a regular basis may be entered without a confined space entry
permit, if in the judgment of Shift In-charge it is safe to do so at that time.

2. GT offline inlet air filter replacement job with proper fuel isolation does not require a
confined space entry permit, until recommended by the Shift In-charge

7. Confined Space Entry Standard


• This standard contains the basic rules to protect personnel from the hazards of entry into
confined spaces.
• Common hazards include oxygen deficiency, flammable vapors, toxic substances, difficulty in
escaping, rotating parts, and electrical shock.
• Examples of confined spaces include tanks, vessels, certain pits, ditches, sewers/septic tanks,
excavations, and vessel support skirts. Entry will be allowed only after compliance with the
specific guidelines of this standard.
• It is mandatory to provide proper and safe means of entry and egress for all confined spaces.
This rule is applicable for all confined spaces, whether these are permit required or non-
permit required.

8. Special Considerations

Prior to confined space entry, all interfaces involved in confined space entry must discuss /agree
on the safety precautions to be taken for safe execution of the job.

9. Shoring and Excavation

Excavations greater than 5 feet must be protected by shoring, before any permit is issued. Soil
banks must be kept at least 2 feet away from the edge of the excavation.

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10. Vessels Having Support Skirts or Similar Confinements


The space under some columns and other vessels is confined by support skirts, structural steel
or other obstacles. All these skirts fall in the category of confined space entry permit unless
specifically exempted in the work permit procedure.

11. Shift In-charge Responsibilities


1. Ensuring that the vessel has been properly cleaned, flushed, isolated and prepared for entry.
2. Locking and tagging of all power-driven equipment
3. Ensuring that rotary equipment is mechanically secured.
4. Ensuring that the internal moving parts are secured to prevent them from turning.
5. Ensuring that blinding, disconnecting or capping of all pipelines attached to a vessel is complete
as required by instructions in the following pages.
6. Ensuring that all isolating valves in the involved pipelines are set in the required positions as
specified in the approved vessel entry procedure for the equipment and are properly tagged.
7. Ensuring that testing for oxygen deficiency, explosivity and toxic materials is complete.
8. Ensuring that all permits have been properly filled, signed and issued.
9. Obtaining agreement with maintenance interfaces on the minimum precautions needed to
perform the work safely.
10. Ensuring that all excavations are prepared as per standard.
11. Providing necessary safety equipment
12. Depute a qualified and certified stand by person.

12. Maintenance Supervisors Responsibilities:

1. Ensuring that their employees are qualified on work permit procedure / comply with the
requirements of lockout and tag out.
2. Ensuring that their employees have locked and tagged the equipment properly where
applicable.
3. Ensuring that rotating equipment has been properly immobilized by mechanical means and /
or de-energized and locked / tagged.
4. Ensuring that all involved pipeline valves are set in the required position as per approved
vessel entry procedure for the equipment and are properly tagged (lines disconnected or
blinded)
5. Ensuring that all permit requirements have been met and that the permit has been signed.
6. Ensuring that all personal protective equipment (PPE) is worn as specified on the permit.
7. Displaying the permit at the job location
8. Obtaining agreement with Operations interfaces on the minimum precautions needed to
perform the work safely.
9. Reading and understanding the permit requirements and ensuring that all permit requirements
have been met before signing the Confined Space Entry permit.

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13. Standby Person Responsibilities:

1. Know potential hazards; beware of the effect of hazards on entrants and how to control.
2. Evaluate any changes of internal conditions because of work being performed within the
Confined space (smoke accumulation, oxygen deficiency during hot job inside).
3. Know how to use entry & rescue equipment.
4. Be familiar with the location of safety shower, exits, emergency siren, and the contingency
plan.
5. Be physically capable of performing the duties assigned. The standby person is responsible for
stopping the job and ensuring personnel’s exit from the confined space if emergency siren is
sounded.
6. Remain at the entry point if anyone is inside the confined space and remain alert for anything
that could affect the employee’s safety (e.g., fumes and noise). Keep restricting entry of
unauthorized persons. Perform rescue that does not require entry into confined space.
7. Avoid the activities that interfere with primary role of attendant.
8. Know / maintain a separate list of all those who are always inside the confined space which
must be placed on the entry/ exit point of the confined space.
9. Frequently confirm that the personnel inside the confined space are all right. Alert and inform
them about any hazard.
10. Ensure air hoses / exhaust pipes and lifelines are intact and remain in good shape. During an
emergency (gas release /fire, sounding of emergency siren), require them to exit the confined
space and then discontinue use of plant air.
11. Assist in safe handling of materials and tools and in conveying messages.
12. Use the walkie-talkie / Whistle or Pager to call help in case of emergency. Communicate with
Control Room to sound the siren in case emergency warrants so.
13. The standby person must not enter the confined space, even in an emergency, until another
qualified standby person arrives and unless he has been trained as a rescuer.
14. The standby person must not allow anyone to enter the confined space to start a rescue
unless he is part of the emergency squad / designated member of rescue team and is wearing
the necessary personal protective equipment.
15. Also mention then name of rescue workers whosoever in the list of confined space entrant
personnel on the back of Confined space entry permit.
16. Should have passed the standby person test & interview, Site management should maintain
up-to-date records of individuals qualified as standby person. The list of qualified personnel
should be displayed in the Control Room.
17. Each standby person should get refresher training at an interval of no more than three years
from the previous training.
18. Standby person should be:
a Permanent employee.
b Trade Apprentice/ TAE at least having six months experience at plant.
c Qualified contract person only (approved by Safety Section).

Note: Use of All SBM’s should be trained and certified by HSE as per request. Approved list of
SBM’s to be maintained by HSE. Refresher training to be provided on yearly basis for TA/TAE’s
and on six monthly basis for contractor.

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14. Preparation for Entry – Cleaning

1. The “Operating Unit” is responsible for properly emptying, cleaning, steaming, neutralizing
and purging (as necessary) all confined spaces before entry is permitted.

2. When it is necessary to enter a vessel to clean it out and there is any possibility of toxic
fumes being released from pockets of crusty or sludgy material, the necessary personal
protective and respiratory equipment must be worn.

15. Preparation for Entry – Isolating Confined Spaces

1. Physically disconnect or blind all process material lines, including nitrogen purging lines. This
includes steam, water or other coolants in coils of confined spaces to be entered. Put blind
as close to the vessel as possible so that all interconnecting lines to main line are also
considered blinded.

2. Pipelines attached to the confined space must be disconnected and completely separated from
the confined space. Isolation of pipeline must be accomplished using the following order of
control:
a Disconnect or blind the pipe side, verifying there is no pressure behind the blind via a
bleed & drain valve that remains open. All valves must be locked out tagged out. Ensure bleed
& drain valve are not blocked with fluid.

b If no flange is available to disconnect ONLY then double block and bleed, verifying there
is no pressure between the blocks via bleed & drain valve that remains open should be
performed. All valves must be locked out tagged out. Ensure bleed & drain valve are not
blocked with fluid. This is to be done only in case blind installation is not possible.

Note: If it is not feasible to isolate the confined by methods above, detailed procedure shall be
developed / approved from GM Production to prescribe how the confined space is to be
protected from release of energy and material into the space. Incident (Near-miss) will be
considered, if confined space is isolated by using option (b) method (mentioned above) in
presence of availability of option (a)

3. Ventilation ducts or stacks open to the atmosphere must be evaluated by the Operations
Shift In-charge before entry to ensure proper protection.

4. When the stack or duct is in dedicated service to the space being entered and is open to the
atmosphere, blinding or disconnecting the stack or duct is not necessary. If the stack or duct
is left open, any other line to the stack or duct should be disconnected or blinded.

5. When the stack or duct is shared with other vessels through a common header, the duct or
stack must be disconnected or closed with a blind of equivalent strength and material of
construction as the duct or stack.

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16. Preparation for Entry – Lockout

1. All power-driven equipment associated with the permit must be locked out in accordance
with the Lock, Tag, Try and Test Procedure.
2. Electrical isolation of Agitated / rotating power-driven equipment inside confined space must
be accomplished using any following order of control, however Try procedure must be
accomplished by both party:
a To be physically disconnected from the power source and tagged, even though the work
may not involve that particular piece of equipment.
b In addition to lock and tag, power-driven equipment shall be disconnected either
mechanically (e.g., mechanical linkage, beaker physically racked out & locked out) or
electrically (e.g., in order of preference by either local removable plug (main power cable
connector removal from DB/JB) or local disconnect and DB/ JB must be locked out Tagged
out. Motor leads are not designed to be repeatedly disconnected; therefore,
disconnection of motor leads is discouraged. Consideration should be given to installing
a local disconnect or plug and receptacle connection to facilitate electrical isolation and
decrease the exposure to potentially energized connection.
c The tag used in the lockout of agitated equipment for confined space entry must list
“Vessel Entry” as the reason.
3. All instruments connected with confined space having power supply of more than 12V should
be put off & locked out tagged out / disconnected /remove the fuse.

17. Preparation for Entry – Removing Obstructions

The areas surrounding the access to confined spaces should be maintained in a safe housekeeping
condition:

1. Access must not be blocked with equipment or materials that would interfere with safe exit
from the confined space.
2. Lines, cords, hoses, etc. must be properly arranged and secured to prevent tripping hazards.

18. Preparation for Entry – Safety Equipment

The following safety equipment is mandatory for confined space entry jobs:

1. An explosivity meter, with sufficient hose / tubing to reach the bottom of the tank from the
manway.
2. An oxygen analyzer, with sufficient hose / tubing to reach the bottom of the confined space
from the manway.
3. If the equipment is entered by means of a ladder, the ladder must remain firmly placed and
tied while individuals are in the equipment.
4. 24-volt light with bulb guard, Proper lighting arrangements should be provided at work area
and points of entry / exit, not less than 54-Lux.

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5. A safety harness and rope for every individual who will enter the confined space and two for
emergency use.
6. An air mask and emergency breathing apparatus (Scott Air Pak for immediate danger to life
and health [IDLH] atmosphere) for every individual who will enter the confined space and
two of each for emergency use. (This applies to confined spaces when air masks are required)
7. The walkie-talkie / intercom / megaphone/ whistle which must be checked to ensure
operability.
8. An exhaust for welding or cutting jobs where hazards can be controlled by ventilation.
(Ejector can be installed for the welding jobs in the vessels to ensure adequate ventilation)
9. Protective clothing as per the job requirement

19. Preparation for Entry – Exemptions

No blinding required for only Cooling Tower (CT-I/II Cell) fans repair confined space entry.
However, cell cooling water isolation, Fan Motor LOTOTOTO and Fan Blade securing with rope
must be ensured by shift in-charge while other requirements of confined space will be followed
as per confined space entry procedure.

20. Preparation for Entry – Secure Rotating Equipment

1. Shafts for fan blades or agitators must be secured to prevent their movement before anyone
enters the tank if a draft or other force can produce freewheeling. If this is not possible, the
blades or shaft must be secured as soon as possible after entry.

2. Securing device on fan blades and agitators may be temporarily removed for the period when
manual rotation is required, provided no safety hazard is created.

21. Preparation for Entry – Blind or Disconnect All Pipelines


1. All pipelines that contain hazardous materials must be positively disconnected or blinded to
ensure that no material can enter the confined space under permit. Disconnected vessel
nozzles must be open to provide air circulation through the top, bottom and / or end(s) of
the vessel.
2. In case the entry is in a ditch or excavation, the Shift In-charge, Shift Coordinator and
Maintenance Supervisor must evaluate the potential hazard and take appropriate action to
eliminate any such hazard.
3. A check list with simple sketch of the blinding / disconnections & double block & bleed must
be attached to the permit or posted on a respective vessel (duly signed off by on duty SIC)
and copy of the same must be available in the control room.

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22. Preparation for Entry – Locking / Tagging Procedures


1. Before signing the confined space entry permit, Operation (SIC/SS) and Maintenance
Supervisor would visually verify that all isolation valves locked & tagged out, blinds and
disconnections tagged out, tag marked “Permit Required Confined Space Entry”. Supervisors
will not delegate verification responsibilities.
2. The valves shall be locked wherever required. See the Valve Lockout / Tag out procedure for
details.

23. Preparation for Entry – Gas Test

1. The atmosphere inside the permit space must be checked for proper oxygen content and to
ensure that no flammable vapors or toxic gases are present. The tests must be conducted in
the following order:
o Oxygen
o Lower explosive limit (LEL)
o Toxic gases
2. Consideration must also be given to the work to be performed and any conditions nearby
that could cause an oxygen deficiency, create a flammable atmosphere or form toxic gases.
3. For First time entry inside a confined space, Gas test to be done through lab sampling. Forced
air circulation should be stopped for better analysis.

Vol. % Effect
Over 19.5% Required for normal support of life
12 - 14% Respiration deeper, pulse up, coordination poor
10 - 12% Respiration faster and shallow, giddiness, poor judgment, lips blue.
8 - 10% Nausea, vomiting, unconsciousness, ashen face. 8 minutes exposure 100%
fatal. 6 minutes exposure 50% fatal.
4 - 8% Coma in 40 seconds, convulsions respiration ceases, death.
0 - 4% Unconscious in 10 seconds, death.

24. Allowable Concentrations for Entry into Vessels:

Before issuing an entry permit, test should be carried out to ascertain the presence of poisonous
gases if any. Lowest allowable concentrations are as follows:

Agent Without Breathing Air Equipment (for 8 Hours)


EDC 50 ppm
VCM 01 ppm
HCL 05 ppm
Chlorine 0.5 ppm
Ethylene 200 ppm (ACGIH)
Oxygen 21% Min. (Same as fresh air)

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Carbon Monoxide 50 ppm


Hydrogen 500 ppm
Carbon dioxide 500 ppm
Methane 500 ppm

Note: If other flammable gas is present, consult the concerned Area Manager or Safety Manager

1. Each area will develop procedures and utilize appropriate & calibrated (as per manufacturer
instruction) testing equipment for determining the concentrations of toxic materials used in
that area.
2. Toxicity readings from commercial meters are reliable only if the equipment has been
calibrated for the contaminant that might be present. If not, then these meters can give a false
sense of safety.
3. Tests must be made at several elevations or locations no more than 30 minutes before initial
entry, at the beginning of each shift, after lunch and as required while the work proceeds.
4. If the concentration exceeds the “allowable concentrations” outlined below, no permit will
be issued unless reviewed by Sub HSE (P) chairman and supplemented by approved
procedures with final approval by MHSE Chairman.

25. Hazards in Confined Space

Temperature

• Temperature in the confined space should not create a hazard for personnel at any time
during the entry, temperature between 41°F (5°C) and 115°F (46°C) is acceptable.
• In case confined space entry is required in a vessel beyond these temperatures, permission
shall be granted after review by Operation’s Manager & Safety Manager.
• Hot or Cold which cause thermal burns or frostbite, this includes above 120° F (49° C) or
cold materials, colder than 32° F (0° C).
Oxygen Deficiency

• The oxygen concentration inside the confined space should be equal to that outside the space,
which is assumed to be 20.9 percent.
• The oxygen test must be carried out by a properly trained and qualified person no more than
30 minutes before initial entry, at least everyone hours thereafter and after any work stoppage
(breaks, lunch).
• Test readings should be taken at several locations and levels within the confined space under
permit.
• If the oxygen concentration inside the confined space is different from that outside the space,
then the reason for the discrepancy must be determined and documented before entry into
the space is authorized.

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• The acceptable oxygen concentration for confined space entry must fall in the range of 19.5
to 23.5percent. However, entry in confined space should not be done without respiratory
protection if the oxygen concentration is below the 20.9 percent.
• Continuous Oxygen monitoring may be required on some jobs, such as interior welding on
small tanks.
• In case of any materials that could affect the safety of the employees, forced air blowers
should be used and continuous oxygen tests should be made.
Explosive Atmosphere
• An explosively meter must be used by qualified personnel to test the air in a permit space at
several elevations or locations no more than 30 minutes before initial entry, at the beginning
of each shift, after lunch and hourly while the work proceeds.
• Results of the explosion test must be entered on or attached to the confined space entry
permit.
Testing procedures are as follows:

1. If the meter indicates more than ZERO percent (0%), the source of flammable vapor must be
identified and removed, if possible. If a minor vapor source cannot be removed, SIC must
evaluate the degree of hazard, and need for additional precautions and then allow entry only
after determining that work can proceed safely (approval from MHSE Chairman is
mandatory).

2. A lack of oxygen will nullify the function of the explosively meter; therefore, this test must
not be made unless acceptable oxygen readings are obtained.

Radiation Hazard

Entry into spaces that have potential for a radiation hazard must be checked and logged by the
site Inspection Supervisor/Engineer and its reading to be informed to production supervisor.

26. Obtain a Confined Space Entry Permit

1. No one can enter a confined space until Confined Space Entry Permit has been properly
executed and authorized. If a Confined Space Entry Permit is issued to any interfaces, no
additional Confined Space Entry Permit is required for other interfaces to enter the same
confined space.
2. However, all interfaces will obtain respective job work permit for which they are being
entered inside Confined space along with isolations (Valves, electrical breakers, radiation,
blinds) and lockout protocol to be followed (lock # number to be mentioned):
3. The permit must be authorized by Shift In-Charge and signed by each Maintenance Supervisor
who is responsible for an employee on the job.
4. Everyone involved with the confined space entry is responsible for ensuring that all aspects
of the permit have been met before signing it.

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5. Persons Entering the Confined Space. Each person, including Supervisors, who intends to
enter must:
a Obtain authorization of his or her immediate Supervisor.
b Read and understand the requirements on the Confined Space Entry Work Permit.
c Counter check Lock and tag as required by this procedure.
d Wear the required personal protective equipment (PPE).
e Sign the permit / or the attached list for entering personnel.
6. Each person intending to enter the permit space, before the job has begun, must follow all of
the above steps and also notify the SIC.

27. Post the Confined Space Entry Work Permit

The approved permit must be posted at the job site, before entering a confined space.

28. Permit Expiry

The Confined Space Entry permit automatically expires when an emergency alarm sounds in the
area or when the shift ends.

29. Provide Rescue Team

• All members of emergency squad or any other employee can be assigned as a rescue team
member by the Operations Manager provided the incumbent is properly trained to use all
rescue and related personal protective equipment for making rescues from the confined
spaces.
• All rescue team members must receive hands-on training in making confined space rescues at
least once every 12 months.
• All team members must have had basic first aid and cardiopulmonary resuscitation (CPR)
training. At least one team member must maintain current certification in basic first aid and
CPR skills.
• Training records must be maintained by Manager Operations.

30. Written rescue plan

A written procedure for calling the rescue team and for rescuing authorized entrants from the
space must be developed, reviewed with personnel involved with the job, and implemented. Non-
entry rescue is preferred unless the retrieval equipment increases the overall risk to the
authorized entrants and/or the rescue team.

31. Developing a rescue plan

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1. The intent of this standard is to allow confined space entry and operations without depending
on rescue services.
2. However, experience indicates that circumstances can arise when rescues occur. It is
therefore important to have a rescue plan for each entry, including identification of the rescue
teams.
3. For all rescue teams or services, the evaluation should consist of two components:
a An initial evaluation to decide whether a potential rescue service or team is adequately
trained and equipped to perform appropriate confined space rescues at the facility and
whether such rescuers can respond in a timely manner.
b A performance evaluation measuring the performance of the team or service during an
actual or practice rescue.

32. Main Elements of a Rescue plan

1. Written rescue plans are specific to the confined spaces and the activities they address. As
such, before each entry authorization, each rescue plan should be checked to see that it is
tailored to the specific activity.
2. The written plan should address the possibility of implementing a non-entry rescue after
sounding the alarm. A non-entry rescue is preferable to entry rescue whenever this can be
accomplished.
3. Protecting rescue personnel is as important as extracting entrants, and in many cases, non-
entry rescue is quicker.
4. Following key elements should be present in all plans:
a The precise identification of the space
b The specified and detailed communication routes for raising the alarm, including what
communication routes (e.g., air horn) are to be used by the attendant(s) or which is
the nearest fire-alarm activation point.
c The equipment specified for a rescue and its location nearby if it is not located at the
point of entry or rescue.
d Who should have a copy of the rescue plan (It is good practice to give a copy of the
rescue plan to the rescue teams before entry starts)?
e The rescue method, including any specifics, any elements to avoid, and any hazards
the rescue team is likely to face.

33. Initial evaluation of rescue service

The capabilities of a rescue service vary with the type of confined spaces from which rescue may
occur and the hazards likely to be encountered in those spaces. Answering the following
questions is helpful in determining whether the rescue service can perform rescues in the
confined spaces. What are the limits about response time?
1. For entry where an atmosphere that is IDLH (immediately dangerous to life or health) could
occur, rescue should be swift (i.e., team standing by at the confined space). In other cases,
swift rescue is desirable but not essential. Can the rescue team appropriately respond?

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2. What is the availability of the rescue service and key personnel, and does it match the times
when confined space entries might be in progress? If the rescue service becomes unavailable
while an entry is underway, is there a robust communications route back so that the entry
can be aborted immediately?
3. For off-site services, has the service agreed to perform rescues at the workplace?
4. Are communications adequate?
5. For rescues into spaces that may pose significant atmospheric hazards and from which rescue
entry and patient packaging and retrieval cannot be safely accomplished in a relatively short
time (i.e., 15 to 20 minutes), are airline respirators (with escape bottles) available for the
rescuers and for supplying rescue air to the patient? If self-contained breathing apparatus
(SCBA) is to be used, does the rescue service have appropriate equipment and training?
6. If the space has a vertical entry over 4 ft. (1.2 m) deep, can the rescue service properly
perform entry rescues? Does the service have the technical knowledge and equipment to
perform rope work or elevated rescue?
7. Does the rescue service have skills in medical evaluation, patient packaging, and emergency
response?
8. Is the appropriate equipment to perform rescues available?
34. Provide Proper Safety Equipment

1. Safety equipment required for a job must be indicated on the permit. Before entry can
proceed, safety equipment must be available at the entry point for each person who is to
enter and for each standby employee.

2. Safety equipment will be checked before each use to be sure that equipment has not exceeded
its usable date or limit and is in good working condition.

3. Safety Harness and Lifeline. Each person in the confined space must always wear safety
harness and lifeline. The lifeline must be kept available at the confined space entry point with
one end secured outside the tank /vessel.

4. If the work cannot be performed with the lifeline attached, the appropriate column of the
Confined Space Entry permit must be checked by the SIC authorizing the permit. Two extra
sets of harnesses and lifelines for emergency use must be available at the location and the
written rescue plan shall identify the essential rescue equipment should be in place.

5. Non-entry rescue equipment should be properly installed and be operational prior to each
entry. Appropriate rescue equipment where the rescue route is to pull the person vertically
upward should include a manually operated winch connected to the entrant’s full body
harness unless such an arrangement increases the overall risk.

6. Whistle: A whistle must be kept available for immediate use by the standby person.

7. Lighting. Lighting equipment (and wiring) inside the confined space must carry no more than
24 volts. Low voltage lights and transformers area available with I&E. Equipment requiring

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more than 24 volts to operate should be used only with a double ELCB + earth wire and after
special permission from Manufacturing HSE.

8. The transformer should be located outside the confined space. Cables of lighting equipment
should not create hindrance in the exit path.

9. Normally, only pneumatic or low voltage (24 volts or less) electric power tools are allowed
in confined space. Electric tools with higher voltage can be used after necessary reviews and
if waiver has been obtained (in writing) from MHSE Chairman. Power for such tools must be
supplied thru an ELCB + earth wire.
Note: Use of Electrical Grinders at Site will only be allowed after grinder inspection checklist
has been filled and approved by EPCL Engineer/ Supervisor in case of Non-Confined Space entry
use and Manager in case of Confined Space Entry Use. This is valid for 01 week.

10. When welding or cutting inside a vessel is to be done, it is critical that adequate breathing air
must be provided to avoid gas pockets and fumes. When breathing air is deficient, a special
air supply welder’s hood must be used.

11. The maintenance supervisor of the employee doing the welding or cutting must initiate and
approve the necessary procedures for this work. Continuous monitoring for oxygen
deficiency and other toxic gases / explosivity should be carried to further ensure a safe
atmosphere. Ejector can also be installed to maintain a constant flow of air.

12. When welding or cutting is to be done inside a confined space, all cylinders and welding
machines should be left outside the permit space.

13. A hot work permit must be obtained and displayed at the work site while carrying out a hot
job. A fire extinguisher and a water hose should be available nearby. Hot work/ Canopy
checklist should be filled before starting the hot job.
35. Actual Entry

1. All personnel entering the space must review the posted requirements on the Confined Space
Entry Permit, make all the required safety checks, place locks and tags as required by the
Lock, Tag, Try and Test Procedure and then sign the Confined Space Entry Permit before
entering the confined space.
2. All personnel who enter confined spaces must understand the hazards, to which they may be
exposed, properly use necessary personal protective equipment, and communicate with the
standby:
a Any individuals joining a job already under way in a confined space equipped with
agitated equipment must check the lock out/tag out of the motor before signing the
Confined Space Entry Permit and entering the confined space.

b Each individual working on equipment is responsible to ensure that it is safe for him
to proceed with the work.

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c Lifelines used in vessels greater than 12 feet in depth shall be kept snubbed with
minimum slack so that the standby person can provide sufficient support to prevent
individuals from falling from the ladder when entering or leaving the vessel.

d Lifelines that have been disconnected in the tank should be reconnected to the
individual prior to exiting the vessel or confined space.

e Job space must be considered when determining how many persons are permitted to
enter.

f Contractor personnel assigned work in the confined space must be authorized by the
relevant Maintenance Supervisor and must follow necessary safety instructions passed
on to them by Operations/ Maintenance Supervisor/ designates.

g The Maintenance Supervisor will be responsible for lock out/tag out/ in place of the
contractor employees.
36. Rescue Services

1. Non entry rescue is preferred and should be used whenever possible.


2. If entry is required for rescue, the rescue personnel will wear personal protective
equipment (PPE) to protect themselves against the hazards present inside the confined
space.
3. The emergency rescue team should be designated and trained accordingly.

37. Confined spaces with unique situations

Some types of confined spaces do not allow for strict adherence to the requirements previously
stated in this procedure. For example:

1. Checking tubes for leaks in boilers and other fired heaters

1. Although the confined space can and shall be isolated from all energy sources for the start of
the entry, the work activity of checking for leaks in tubes for boilers or other fired heaters
typically requires the introduction of water for hydrostatic testing.
2. This is allowable for this work activity under the condition that the energy source is and
remains at a non-hazardous level during the full duration of the entry.
3. The following precautions shall be used when planning and performing checks for leaks in
boilers etc.:

a Hazardous materials or compressible gases shall never be used for leak checking when
entry into the boiler or fired heater is required for inspection.

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b Only use water that is considered non-hazardous (may contain water treatment
chemicals, but not sufficient to require additional chemical hazard PPE).
c Use entry personnel who are trained in the specific hazards and applicable controls of
boiler maintenance.
d Entrants who are inspecting for leaks must wear sufficient PPE to protect them from
physical hazards associated with splashes and spray (e.g., face shield and rain suits, as
applicable).
e If the leak is sufficient to flood and/or pool (sludge level up to 9” maximum at work area)
in the confined space, the accumulated and source water shall be removed before major
leaks are repaired.
f If the leaks are not large enough to be seen from outside the space, entry shall be made
only once the potential for a catastrophic rupture has been eliminated (i.e. entry to be
made 10 minutes after pressure has stabilized). All services shall be disconnected prior to
entry.
g If the leaks are large enough to see from outside the space, the water pressure shall be
removed and released, and the tubes shall be re-isolated prior to entry.

2. Other spaces with hazards similar to confined spaces

• There are areas or locations that do not meet the confined space criteria but may pose similar
hazards to a confined space should entry occur (e.g., putting one’s head inside a 12-in. [30-
cm] diameter pipe or duct or into a nitrogen purged pot).
• In these cases, a work hazard assessment shall be performed, and appropriate controls shall
be used to address these hazards.

3. Inert gas purging of spaces

• Inert gas purging of confined spaces can create atmospheric hazards close to openings into
the space but still outside the defined confined space.
• Precautions specified for entry preparation and for during the entry when such purging is in
progress should include definition of the hazardous zones around openings, provision of
barricades to prevent inadvertent access to these zones, and placement of signs to warn
people.
• Atmospheric testing should be used to verify that defined hazardous zones are correctly sized.

4. Dikes

• In many cases, dikes are not obvious confined spaces; however, they can be regarded as
equivalent to open-topped tanks.
• Which dikes are confined spaces and which are not is a complex issue involving judgment.
The definition of a confined space applies but with particular emphasis on the elements of
restricted means of entry and exit and the presence of additional hazards.

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• A dike that has vertical walls 4 feet (1.2 m) high or higher and does not have fixed steps from
within the dike to the top is deemed as restricting entry or exit.
• When additional hazards may be present, they override height considerations or the presence
of fixed steps.
• The determining aspect is the feasible exposure to physical or chemical hazards within the
diked area. An example of a physical hazard is when the pipe layout inside the dike hinders
exiting the dike.
• An example of a chemical hazard is a heavier-than-air gas stored in the tank, used in the area,
or piped through the diked area.
• In this case, the extent of the hazard might depend on the task to be performed. The normal
approach with chemical hazards is to isolate possible sources and then prove that the area is
a non-permit confined space.

5. Excavations and trenches

• A trench, permanent or temporary, and excavations are similar to dikes in that the approach
adopted involves judgment.
• The physical hazard involves the ease of exiting the area and is readily assessed. For chemical
hazards, the assessment addresses whether or not people may be exposed to chemicals,
usually gases.
• A key aspect is whether the task involves people working with their heads below the trench
or excavation lips. Hence, digging a trench that is 4 feet deep is unlikely to create a confined
space, but lying flat inside it to perform a task would.
• The normal approach with chemical hazards (where possible) is to isolate possible sources
and then prove that the area is a non-permit confined space.
• The temporary nature of trenches and excavations that might be considered confined spaces
makes it impractical to include them in any site list of confined spaces.
• However, appropriate warnings should be on display at the location in keeping with the
principles set out in this standard.

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9.6 Excavation and Civil Work Permit (White Card)


1. Excavation Work Permit must be obtained for all excavations greater than 1 feet in depth.

2. Excavation or civil work within or outside the process units battery limits will be Co-signed
by Project Engineering Manager and the Electrical Manager or their designates, and authorized
by the Shift In-charge.

3. The permit must be made out for a specifically marked area and job only.

4. The operator on powered equipment to be used for excavation must sign the permit to
indicate his understanding of the safety precautions to be taken. In case he is illiterate, his
supervisor must discuss the job scope with him and sign the work permit on his behalf.

5. Excavation work by powered equipment is prohibited closer than four feet to any
underground cable/pipe.

6. Initial digging in proximity to red concrete must be done cautiously by hand. An Electrical
Work Permit for excavation at or near electrical equipment is required in addition to the
Civil and Excavation Work Permit.

7. Red concrete or Bricks must not be broken or cut without written approval of the Electrical
Manager.

8. In case, an excavation is to be continued for more than one day, a blanket permit to be issued,
daily co-signing of the permit by the Electrical and Project Engineers is not required provided
there is no change in the job scope (length, width and depth of the excavation) and permit
issued on the starting day of the job is available for reference purposes.

9. Also, the area to be excavated is properly marked and underground electrical cables and
piping etc. have been highlighted.

1. Responsibilities for Excavation Work Permit

• It is imperative to ensure that during excavation, no underground piping, electrical cables,


cathodic protection, or grounding system will be encountered.

• In case the piping or electrical cables are present, and excavation is still to be carried out, this
should be in the knowledge of all interfaces so that necessary safety measures are taken not
to damage the piping or the cables during excavation.

• Following interfaces are assigned the responsibility to check the presence of underground
piping/electrical cables.

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1. Project Engineering Manager / Designate

• He will ensure that updated/evergreen drawings for underground piping are available for the
total site.
• He should consult the relevant drawings for the presence of underground piping before
signing the permit. If needed, field visit should be carried out to mark the area. In case of
doubt, supervisor must be consulted before signing the permit.

2. Electrical Manager / Designate

• He will ensure that all drawings for underground electrical cables, cathodic protection or
grounding system are available and updated on evergreen basis.
• The drawings must be consulted before signing the excavation permit. Area must be visited
if needed and consultation with the supervisor should be carried out in case of doubt.
Electrical must confirm the location of the cables through cable locator before job execution.
• Cable locator to be used for walls as well. In case of unavailability of cable locator; complete
power of that particular room or area to be switched off.

Note: Wrong information can jeopardize the safety of personnel and equipment and may result
in a serious safety incident.

2. Shoring Requirement

Shoring standards for excavation will be followed in case of excavations greater than 5 feet.

3. Shoring standard for excavation:

1. Shoring is required to prevent danger to an employees working in an excavation from fall or


dislodgment of materials forming the sides of the excavation. An employee should not enter
an excavation or trench that does not comply with this standard.

2. These standards shall apply to all excavation work to be carried out at the Plant, Offsite and
elsewhere under EPCL supervision/ jurisdiction.

3. All excavations greater than 5 feet or closer to a wall than the depth of the excavation shall
either be shored or excavated in ½ : 1 side slope (as shown in Figure) to protect the
employees from cave-ins or sliding material.

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EXCAVATED AREA
1’

1’
½’ ½’

4. In locations where sub soil water is encountered at a depth less than 5 feet, shoring shall be
done at all depths.

5. Wooden planks measuring 4 ft. x 15 in x 1½ in shall be used for shoring work. These planks
shall be used only for shoring purpose. In case of non-availability of wooden planks ¼ in or
3/8 in steel sheets can be used. Scaffolding planks can also be used.

6. While excavating within a distance of 2 ft. or less from an existing foundation, in case a part
of the shoring is installed at a depth greater than the depth of the foundation, this part shall
not be removed or disturbed during backfilling.

7. If an excavated area is left as such overnight or for a few days, water/sludge may seep through
the shoring necessitating reworking on the trench. All water/sludge thus encountered shall
be pumped out immediately prior to entering the excavation.

8. Excavated areas shall not be left as such for more than 2 days. All excavations on which no
work has been done for 2 days shall be inspected immediately prior to entering them.

9. Barriers shall be provided on all sides of excavations regardless of excavation depth.

Note: In certain special cases the concerned Engineer, with the approval of Chairman Sub- HSE
(Mechanical), may modify or waive shoring requirements.

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9.7 Vehicle Entry Permit (Luminous Orange Card)


1. The vehicle entry permit must be obtained before any vehicle equipped with an internal
combustion engine may enter the battery limit of process and utilities area where vehicle
entry is not normally permitted.

2. All vehicles entering the process should have a flame arrestor installed at the exhaust.

3. Special instructions must clearly be given to the driver / vehicle operator regarding hazards
associated with the job and the area in which the job is to be carried out.

4. Vehicle Entry Permits will be authorized by Shift In-charge.

5. In case a job requires the use of a vehicle such as crane, forklift or pay loader a Vehicle Entry
Work Permit must be obtained. If the actual job performed by the vehicle requires lifting, a
separate Lifting over Process Equipment work permit must be obtained.

6. It must be noted that no Cold Work Permit is required in addition to the Lifting over Process
Equipment Work Permit when a job is being carried out using a crane or fork lifter.

7. In case the vehicle is to perform a job such as transfer of material (lube oil, chemical, lime,
etc.) inside plant battery limits in which no lifting is involved, only the Vehicle Entry Work
Permit would be required. However, the description should be clearly state that the vehicle
is being issued for transfer of material.

8. It is the responsibility of execution team to ensure the health/condition of vehicle before


utilizing it in any activity at site (Responsibility: Permit accepter).

9. At PM&S vehicle entry permit is valid only for stationed Crane and Hydra Lift.

10. Do not allow without spark arrester vehicle / portable generator driven equipment in
classified area including portable fumigation machine.

11. Cleaner / helper is mandatory with driver while vehicle entry in operating areas. Single Vehicle
entry work permit is sufficient for single vehicle for a single post.

12. If a vehicle such as fork lifter or pay loader is used for transferring material inside the plant
battery limit, an additional cold work permit will not be required and the purpose should be
clearly mentioned on the vehicle entry work permit itself.

13. Vehicle Entry permit shall not be issued to Maintenance for Cranes until its Fitness certificate
(sign off by Inspection Engineer) and Crane daily inspection checklist is not available with
crane crew.

14. Do not drive through a cloud of VCM / HCL or any other combustible gas/ vapor, even if a
road barricade has not been put up.

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Note:
a Battery operated Fork lifters/ Golf carts are not allowed to enter Process battery limits.
b Petrol driven vehicles are not allowed inside plant battery limit.
c LPG & CNG cylinder fitted vehicles are not allowed to enter EPCL Plant site

1. Exemptions

1. No vehicle entry work permit required for E-Pond, off sites etc.
2. In case of emergency or weekly/ quarterly exercise drills, vehicle entry permit is not required
for Ambulance/Fire truck.

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9.8 Lifting Over Process Equipment Permit (Navy Blue Card)


1. The Lifting over Process Equipment Work Permit must be obtained before handling of any
load by crane or other lifting devices over the process lines or equipment (fork lifter, hydra
lift, pay loader etc.).

2. Lifting over Process Equipment Permit will be authorized by the SIC. Lifting over work permit
is required while using overhead cranes (example pump house, compressor crane).

3. In case, a potential for process incident is present (as mentioned below), following checks
need to be made:
a Ensure that adequate contingency plans are available while handling loads by crane or
other lifting devices over process equipment (vessels and piping) containing hazardous
materials which can potentially endanger personnel on or Off the Site in case of loss of
containment.
b Process Service lines and Equipment are vulnerable to damage from dropping of
suspended loads on them. Primary emphasis should be placed on using proper rigging and
lifting practices to maintain control and prevent falling / dropping of the load.
c Lifting over process lines and equipment could expose the environment and the
equipment to danger from a falling load. Lifts over process lines or equipment require a
'Lifting over Process Equipment Permit'.
d In case, the lift has the potential for a Serious Process Incident, then a thorough written
review of the lift is necessary. The permit ensures that adequate safeguards have been
taken to minimize the effects of an incident occurring from hoisting activities.
1. Responsibilities
1. The Maintenance / Project Supervisor will contact the Operations Supervisor and explain the
nature of the work. He will also explain the path the lift will take.
2. If the Operations and Maintenance interfaces agree that there is no potential for a serious
process incident occurring, should the load or boom drops, only the date, time and location
of the lift need to be filled out on the permit (Upper portion of the permit) along with
authorization by the Operations SIC.
3. In case, a potential for a serious process incident is present, a contingency plan must be
developed and communicated to those, who could be affected. The remaining portion of the
permit will now be filled by Maintenance, Area Engineer and approved by the Shift In-charge.
The Maintenance Supervisor will cosign the permit.
2. Procedure

1. In case, there is a potential for a Serious Process Incident occurring should the load or boom
drop, a contingency plan should be available. The permit must be filled out which addresses
the following:
a Personnel safety
b Impact on people not directly involved in the job
c Communication of lift to all concerned

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d Process releases and their impact On and Off the site


e Loss of services due to ruptured lines
f Equipment damage
g Downtime to repair the damage

2. Bumping process lines and equipment with rigging equipment can also cause a process
incident. Even if a lift does not occur directly over such equipment, it may be close enough
to warrant the use of this procedure.

3. Many lifts offer flexibility in location of the rig and also what path the boom takes to reach
the object. Careful consideration should be given to where the rig sets up.

4. With planning, the number of process lines/equipment under the lift may be reduced or
eliminated. Doing so will minimize the consequences of a potential accident.

5. The authorized permit shall be reviewed with all those directly involved in making the lift and
those potentially affected, including operators required to secure the plant should a hoisted
load fall and cause a process leak.

6. If the permit is required to go beyond the end of the shift, it can be extended as per normal
procedure. Before extending the permit, the SIC will ensure conditions of the lift still match
the permit. If they don't, a new permit will be issued.

7. Also, the SIC will be responsible that all new employees, both those directly involved and
those potentially affected by the lift understand necessary details and safety precautions
before the job is carried out.

8. If a lift is to be made which crosses process lines with multiple production areas responsible
for the pipelines, a separate permit shall be obtained from each production area.

9. Permanently mounted hoists, overhead cranes, and lifts covered by an area procedure are
exempted from requiring this permit. Lifts made with chain blocks do not require this permit,
but such lifts should be carefully thought out as to the potential consequences should the load
drop.

10. In addition to the permit, established safe practices for lifting must be followed, such as
barricading under the boom, inspection of rigging materials, using tag lines, etc.

11. A Lifting over Process Equipment Permit shall be used in addition to other required permits,
such as a Vehicle or Hot Work Permit. An additional cold permit will not be needed for the
lifting over job.

12. In case of high wind velocity 20-25 mph or 30-40 kmph (as per OSHA), work at height jobs
and rigging activities need to be stopped. It is the responsibility of permit authorizer to assess
the situation before issuing lifting over permit in such conditions

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13. In case of load exceeding 4.0 MET, a rigging card with proper authorization is to be attached
with the permit and rigging card must be in the field/ area to ensure all the check.

9.9 Radiography Work Permit (Yellow Card)


1. This permit is intended to ensure protection for people working in the surrounding area from
exposure to radiation while radiography is being carried out.

2. Radiography Work Permits will be initiated by the Inspection Supervisor / Engineer and
approved by the Shift In charge.

3. The procedure established below presents some of the basic steps required as safety
precautions in the field of radiography.

4. This is intended to be a measure of good practice to provide protection for people working
in environment applicable to EPCL. The duties and responsibilities of the various groups are
also briefly outlined.

5. Under normal circumstances, a 24 hours’ notice regarding intended place and time of
radiography work will be given to the Production Department except in emergency cases
(Responsibility: Inspection).

6. The Manager/Shift Coordinator will ascertain that area can be cleared of people as and when
required and issue a Radiography permit for the job. (Responsibility: Production).

7. The radiographers will proceed to setup and position the film, after which the radiation area
shall be roped off. (Responsibility: Inspection).

8. Before the source is ready for activation, an adequate number of warning signs shall be
conspicuously displayed on the out-skirt of the cordoned area.

9. The out of bound limit is dependent on source strength used and shall be determined by
radiographers. Personnel equipped with megaphone can also be deputed to keep the affected
area clear of people. (Responsibility: Inspection/ Maintenance).

10. Prior to radiography operation, the radiographers and their assistants shall ensure that no
unauthorized personnel are within the radioactive sphere, i.e. all other work carried out
either above or below or at grade within the specified safe distance from the radioisotope
must be temporarily abandoned until completion of the radiography process. (Responsibility:
Inspection).

11. A physical radiation survey around/outside of the roped off area shall be carried out during
radiographic operation. This is usually accomplished by using a radiation intensity meter. The
radiographer is responsible for increasing the off limit area if the device detects radiation
above the acceptable level. Inspection will verify that level at limits of roped area is acceptable.
(Responsibility: Inspection).

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12. At all times during the exposure, a competent and qualified radiographer must be at the site.
He must be capable of returning the isotope to its camera at any time when circumstances
so warrant. (Responsibility: Inspection).

13. After the aforesaid radiography operation is complete, the radiographers shall return the
isotope to its camera. This is ensured by physically monitoring the work area and the sealed
source when it is in the off (shielded) position.

14. In case of any emergency such as malfunctioning of any part of the radioactive source
rendering it immobile, the radiographers shall be capable of handling the situation that arises.
The area shall be maintained as off limits to unauthorized personnel until it is declared safe
for re-entry. (Responsibility: Inspection).

15. On completion of radiography, all ropes and signs will be removed, the area cleaned up and
Work Permit returned to Production Department. (Responsibility: Inspection).

16. All personnel involved in actual transportation of X-ray equipment and identification of
equipment to be X-rayed should wear 'film badges' that measure the accumulated dosage of
radioactivity. (Responsibility: Inspection).

17. Radiography will be performed by EPCL approved 3rd party contractor under supervision of
inspection.

18. In case radioactive source is to be taken/moved in the vicinity (about 50 feet) of boilers and
process air gas turbine, the Inspection Supervisor should communicate the same to
'Operations' and obtain their concurrence/ permit before such an activity.

19. The barricading distance clauses at back side of radiography permit must be filled while permit
preparation. These clauses address the distance that need to be barricaded in all directions.
This clauses portion needs to be filled by inspection person. (Responsibility: Inspection).

1. Radiation Hazards
• The effects of radiation are largely the ionization and destruction of the blood and body cells
and tissues. Many secondary effects can be caused by the ionization process.
• Many of these processes are reversible i.e. the damage caused can be reversed by the normal
reparative mechanism of the body. However, in case of a large dose or continued over
exposure, non-reversible damage will occur.
• The most common effects of large and continued over-exposures are leukemia (blood cancer)
bone and lung cancer, tumors, etc.
• The radiation exposures are cumulative and lead to delayed illnesses. The symptoms and
expected effects of acute and high degree of whole-body radiation exposure are vomiting and
nausea in nearly all persons exposed on the day, followed by other symptoms of radiation
sickness.
• For very high exposures, depending upon the degree of radiation, about 10-100% fatalities
within 1 to 6 weeks’ time are expected.

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2. Exposure Reduction
• The three methods of reducing exposure are:
a Increasing shielding.
b Decreasing the time of exposure.
c Increasing the distance between the worker and the radiation source.

• Shielding is used mostly for storage of the radiation source and is incorporated in the original
design of the camera.

• To reduce the exposure time, best approach is to train a number of technicians and the
rotation of these personnel for handling the radiography / radiation related work.

• The factor of distance is the most valuable means of controlling the radiation exposure.

• Radiation decreases according to inverse square law, i.e. doubling the distance drops the
exposure to 1/4, tripling the distance to 1/9, and so on. The affected area should be properly
cordoned off and suitable warning signs must be displayed at conspicuous places.

9.10 Other Work Permit Exceptions:


For the following jobs, work permits will not be required by the laboratory personnel, however
Area Engineer/ Area Operator will accompany lab personnel for the collection of samples. All
work permits exempted jobs list for respective unit shall be approved from Sub-HSE (P) and its
updated list to be readily available in CCR.

Sample Collections:
a VE-1201 sample point
b VE-8601 sample point
c VE-8101 sample point
d Wastewater Sample Collection
e PVC Resin Sampling

9.11 Blanket Permits:


1. Blanket (Civil & Excavation and Cold) work permits shall be initiated by the shift In charge
and approved by the Operations Manager and issued to the maintenance team for a specific
job/area on equipment and for a time period of maximum 7 days.
2. However, keeping in view, the hazards associated with the job, all the interfaces should discuss
and agree on specific precautions to be taken while executing the job. Blanket work permit
will be issued as follows:

1. Procedure for Issuing Blanket Permit

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1. The Maintenance. Engineer / Supervisor shall request a Blanket permit from the shift in charge.
2. The Manager Operations must make certain that all prescribed conditions have been met for
the issuance of the Blanket permit.

3. The Maintenance/Project Engineer shall countersign the permit where the Maintenance
person ordinarily signs it, and then assign his EPCL supervisor to work.

4. The Maintenance/Project Engineer accepts the responsibility of safely placing his men to work
when Blanket permits are issued and explaining to his men the conditions under which the
permit was issued.

5. Daily safety talk on working place is to be conducted to any change in working environment
for example, proper ventilation, and protection from over-head hazards, the wearing of
proper protective equipment etc.

2. Use of Permit by Incoming Shift:

• Permits may be passed from one Maintenance EPCL supervisor to the incoming shift or to
his reliever till the time the permit is valid, provided the relieving Maintenance EPCL person
is doing the same work in the same location for which the original permit was issued.

• Extension of the permit must be endorsed in the field by the incoming shift in charge, within
one hour of start of shift (before expiry), but a work permit can be extended only once.

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9.12 Work Permit Protocols for PM&S:

1. PVC Plant Operations and PM&S Overlap:

At the interface of PVC Operations and PM&S, following work permit authorization will be
followed:

1. Till silo inlet Diverter Valve d/s flange


• Authorized by: PVC Operations

Backend area operator of PVC operations will check the conditions and sign the permit.
Supervision of the job will be PVC operations responsibility.

2. From silo inlet Diverter Valve d/s flange, silos and All Instruments on Silos Till silo bottom
Slide Gate Valve (Including Slide Gate Valve)
• Initiated by: PM&S
• Authorized by: PVC Operations

EPCL PM&S Supervisor will check the conditions and sign the permit. Supervision of the job will
be PM&S responsibility.

3. Downstream of Silo bottom slide Gate Valve

• All work permits authorization from downstream of Silo’s bottom slide Gate Valve belongs
to EPCL PM&S supervisor, any job requiring LOTOTO of PM&S equipment must be done by
PM&S Supervisor.

• For jobs on silos, all instruments on silos, slide gate valve and downstream of slide gate valve,
PM&S Supervisor will check the conditions during job execution.

2. Work Permit EXCEPTION for PM&S

• Work Permit Certified Lead Man (Contractor) at PM&S can handle work permit as an Area
Engineer/ Operator ONLY for Cold, Instrument and Electrical work permit(s) except those
involving live circuit.

• Additionally, hot work permit at PM&S shall be initiated by PM&S Tier III & Tier III Supervisor,
Authorized by MSO and signed off by PM&S Supervisor as Area operator.

Note: For off hours, all work permits except cold permit at PM&S will be initiated by PVC SIC.

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SECTION-10 LOCKOUT, TAGOUT, TRYOUT &


TESTOUT
10.1 Introduction
• This document describes the key elements of an energy control program that must be met
to comply with OSHA lockout requirements contained in 29 CFR 1910.147, Control of
Hazardous Energy.

• Importance of taking all possible precautions for ensuring the safety of an individual working
on equipment or process or pipe that has been shut down for repairs, alterations, or cleaning
cannot be overemphasized.

• The use of locks and tags not only help ensure safety of personnel, but also prevents damage
to the equipment.

• The following procedure describes the lock, tag, try and test actions for safe handing over of
equipment or process or pipe for maintenance activities.

• The specific written instructions for adequately de-energizing a piece of equipment or process
or pipe must be followed before implementing this generic lock, tag, try and test out
procedure.

10.2 Principles
All sources of hazardous energy shall be identified prior to initiating any lockout / tag out/ try
out/ test out. All sources of hazardous energy shall be removed or controlled prior to
potential exposure to the hazards.

Examples of removing or controlling hazardous energy are as follows:

• Disconnecting power and discharging any capacitance.


• Isolating pressure sources and releasing the pressure.
• Stopping rotating devices and securing them from further movement.
• Releasing stored hazardous energy.
• Lowering or securing equipment to prevent movement caused by gravity.
• Protecting equipment from external forces (e.g. wind) that may cause movement.
• Fuel-powered, engine-driven equipment (sometime called portable equipment) must be
rendered inoperable by secure means (e.g., by removing the battery cables or removing
the spark-plug wire or equivalent).

Note: Push buttons, selector switches and other control-circuit type device are not .
hazardous energy-isolating devices. Control and solenoid valve are not adequate
means of providing isolation for fluids.

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10.3 Key Elements


1. All Authorized Employees / Affected Persons must be trained in the control of hazardous
energy procedures that apply to their work activities. This training and refreshers must be
documented, and records kept.

2. Safety Section must audit the energy control program at least annually. This audit should
include testing of the Authorized Employee’s knowledge of the energy control program in
the area being audited. The audit must be documented and to be used to meet the refresher
training requirements.

3. The de-energizing procedure can incorporate a generic lock, tag, try and test procedure
described in the following pages.

10.4 LOTOTOTO General Requirements

1. Before an individual commences work on or inside equipment or process or pipe where


electrical, hazardous, or potential energy could be encountered, all relevant electrical
breakers or valves must be isolated, locked and tagged in the proper position (open or closed
as per exiting SOPs) with a properly executed Danger Tag and Lock.

2. All requirements of “opening lines & Equipment procedure” must be fulfilled before starting
the locks/tags (Flushing, purging, clearing, verification etc.).

3. The locks and tags are required to be installed on all process gas lines/services including
steam, and pressurized water above 5 bar (details are given in section 1.4).

4. Any job which is to be carried out within the suction and discharge isolating valves of any
pump shall be treated as a locked & tagged job, i.e., pump motor must be locked & tagged.
This is because of few pumps where impeller is exposed after removing suction or discharge
line and human exposure to pump rotating parts is possible if the motor is switched ‘ON’.
Locked & tagged requirement mentioned above must be followed on all the pumps even if
the human exposure to mechanical parts is not evident.

5. If for any job on piping or other equipment (strainers etc.), positive isolation with block and
bleed is available, then the motor lock out / tag out is not mandatory. Whereas Valve LOTO
must be performed for such jobs.

6. If double block and bleed is available and it has been established/ensured that the valves are
not leak through, there is no need to install the blinds, the isolating valves and bleeders shall
be locked and tagged. However, for confined space entry blinds cannot be exempted.

7. Electrical LOTO is mandatory for painting job at any part of pump in off condition. Painting
job on running pump is not allowed.

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8. EPCL employee must apply his own interface lock, tag, and then TRY the effectiveness of the
lockout when doing maintenance, or repair work. (If 10 EPCL employees from same or
different interfaces are working on equipment or process or pipe at any one time and there
is only one lockout point, each employee must apply his own lock (and tag) using a multiple
locking device.

Note: If 3 or more interfaces are working on one energized


equipment then multiple locking device should be installed on
breaker for locks

10.5 Department Locks and Tags


1. Each interface whose nature of work requires usage of LOTOTOTO shall be provided with
separate-colored locks. The locks to be installed by Production should be red in color. The
locks to be used by other department will be color coded to differentiate various
departments.

2. The following color coding will be followed on Site:

• Production: Red
• Maintenance : Yellow
• I&E : Green
• Other Interfaces : Blue

Other
Production Maintenance I &E
Interfaces

3. Respective “Do Not Operate” tags of all interfaces have been pictorially represented below

4. As per revised guidelines after maintenance lockout, Tags to be installed and signed by EPCL
Maintenance Supervisor on breaker in MCC only after verifying the Try out step.

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Operation Maintenance I&E Other Interfaces

5. All other material like tags, multiple lockout devices will be available at all Operation Units.

6. All locks and tags must be durable, easy to remove, easily identifiable, standardized by color
and size.

7. An ever-green record of locks issued should be available with the Area Manager. The spare
keys of all the locks must be kept in the safe custody of the Area Manager.

8. For Turnaround only, Production / Maintenance will prepare special locks with their specific
color codes and marked specific numbers. The locks will be used by Production SIC/
Maintenance Supervisors who have qualified the Work Permit Procedure.

9. These locks should be used only for lock out/ tag out procedure. It must not be used for
locking personal lockers or unauthorized items.

10. Never lend or borrow a lock or remove someone else’s lock or tag.

11. If exceptions to the procedure appear necessary, the safe procedure for such work must first
be determined by the Manager with the involvement of Safety Section and approval of the
Sub HSE (P) Chairman. Manager will authorize usage of the new detailed procedure and follow
that job from beginning to end to ensure that the procedure is carried out as outlined.

Caution: There is one additional consideration that needs to be addressed to ensure the
validity of the try step in procedures to control electrical energy. The purpose of trying the
local ON/OFF switch is to ensure that the relevant electrical main switch was turned off
(opened).

12. If a condition exists that prevents the equipment from operating (i.e. a motor from running),
even if the electric main switch for that equipment is still “On” (closed), then the try would
not be valid. Label of the breaker is the only check in this case. This is not sufficient to stake
your life on it. The two most common conditions which can render the try step invalid are.

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13. The equipment is damaged and would not operate, even if energized (i.e. a motor which has
open windings).

14. An interlock is not satisfactory and has open relay contacts in the control circuit.

15. If the equipment is operable, the simplest way to ensure validity of the try step is to first try
the start switch before turning the breaker off and observing that the equipment operates.
Then, ensuring that nothing else changes, turn the breaker OFF and try the local ON/OFF
switch again, observing that the equipment does not operate now. This is sometimes referred
to as a “positive-negative” try.

16. If the equipment will not operate when the local ON/OFF switch is tried with the breaker
turned ‘ON’, the cause must be ascertained, and the fault must be rectified to allow a valid
try.

17. For example, if the reason is because the motor has open windings, then it will be necessary
to open the terminal box on the motor so a voltage measuring device such as multi-meter
can be used as the indicator for the positive-negative try.

18. If the reason is because an interlock exists, then the contacts on the interlock relay can be
blocked. But remember, whenever a relay is blocked for the try, “Production” should ensure
that it is unblocked before the equipment is returned to service.

19. Checklist should be used for this purpose. When measures such as these are taken to validate
a try, remember that electrical conductors must always be treated as if they were energized
until it has been proved they are de-energized.

10.6 Electrical LOTOTOTO


1. First Party (Production Department):

1. The production shift in-charge or his designate shall make sure that the identification on the
local start/ stop control concurs with the identification on the circuit breaker in the switch
gear room.

2. In the switchgear room, the production Shift In-charge or his designate shall get the breaker
opened (OFF) by the post Assistant Engineer and tagged with a “Do Not
Operate”. The post Assistant Engineer shall sign and put date and time
on the tag

3. The production shift in-charge shall ensure that the right breaker has been
de-energized by operating the local start/stop switch and get it verified
from DCS Engineers by putting manual Run command from control
station. He shall then put the local switch in OFF position and put a “Do
Not Operate” tag having his signature, date, and time on it. (Refer to the
Positive-Negative LOTOTOTO guidelines mentioned previously)

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4. Production Shift In charge shall then ask the area engineer to place a numbered Red lock
(with a small tag showing the lock no. and location it has been installed) on the breaker and
place the key in the designated place in the keyboard inside CCR. A small key tag will be
attached to it indicating the relevance of that specific key.

5. Area engineer will fill out the record file of LOTOTOTO (placed at the DCS Board) with his
Name, Date, Time, Lock Number, Specific Unit, Description of the Job and Signature. Incase
job gets competed Lock Removal Date and Time is to be mentioned on the record file along
with the on-duty area engineer name and signature.

6. Each lock shall have only one key. However, a set of numbered spare keys will be available
with the operations manager for use in emergencies.

7. Additional cold work permit is required for Rack-in/Rack-out of 6.6 KV or higher voltages
breaker by Electrical technicians.

Note: In case more than one start/stop switches are installed for the same equipment the
above procedure will be carried out for all of them.

2. Second Party (Maintenance/ I&E/ Other Interfaces):


1. Must ensure proper identification of equipment breaker as mentioned on work permit.

2. Warrant that the steps mentioned above have been taken.

3. Place the numbered Yellow/ Green/ Blue on the breaker and retain the key in designated key
boxes. He shall acknowledge this fact by signing the work permit prior to starting the job.

4. Second party locks (Yellow/ Green/ Blue) will be available in respective workshop areas of
each interface.

5. Each lock shall have only one key. However, a set of numbered spare keys will be available
with the Maintenance Manager for use in emergencies.

6. If more than one work permit has been issued for different jobs on the same equipment, then
multiple locks shall be installed separately by the personnel working on the equipment.

3. Third Party (I&E) (Test Out Step)


Electrical supervisor/ Designate will test out the respective de-energized circuit with the help of
certified equipment to counter check that the system is free of any electrical energy and signed
off the respective tag in the ‘Switch Gear Room’.

Note: Test out is not required on 6.6 KV. Jobs to be performed after rack out only. For
details refer to section “Guidelines for LOTOTOTO”

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4. Locks and Tags Removing Procedure

1. After the work has been completed the maintenance and/ or electrical technician shall remove
the yellow/ green/ blue lock and return the hard copy of the work permit in exchange for the
white copy.
2. The Area Assistant Engineer will inform the shift in-charge about completion of the job, and
will get authorization for removing red lock and tag for closing the breaker.
3. In case more than one work permit has been issued for the same equipment, then all these
work permits shall be exchanged before the red lock and tag is removed and the breaker
closed.
4. When high voltage breakers are to be racked in this should be done in the presence of
electrical technician. Additional cold work permit is required for Rack-in of 6.6 KV or higher
voltages breaker by Electrical technicians.

5. Exceptions:

For equipment which does not have lock out facility, the equipment shall be made safe by
disconnecting its power source from downstream of the circuit breaker and placing a yellow tag
‘Wire Disconnected/Circuit Incomplete” on the disconnected device.
Note: A separate electrical permit is required for disconnecting wires after breaker is put
on “OFF” position

6. Disconnected or Incomplete Wiring Situation:

1. The Shift in-charge and Electrical technicians shall follow the


LOTOTOTO procedure as described above except installing the
lock.
2. After making sure that the circuit is de-energized, a qualified
electrician shall disconnect the circuit breaker output wires and
tape them separately on the circuit breaker. Check with voltage
meter or tester that there is no current in the wire.
3. The Production Assistant Engineer and the Electrical technician
shall tag the switch with a yellow tag “Wire Disconnected/Circuit
Incomplete”.
4. The electrician should note on the tag where the wiring is
disconnected or circuit is incomplete, date time and sign the tag, and shift in-charge shall
ensure it before job to be executed.
5. After completion of the job, the shift in-charge will authorize reconnection of the wiring thru
a work permit.
6. After the wiring has been reconnected, the yellow tag shall be removed by the Area Engineer.

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7. Cutting of Padlocks in an Emergency at Breakers:

1. To ensure personnel / equipment safety prior to energizing a breaker for which padlock(s) at
the breaker are to be cut.
2. Production SIC is to specify the equipment(s) that will be energized by the breaker at which
padlock(s) to be cut.
3. To verify that no work is left incomplete on the equipment, SIC will ensure that hard copies
of all work permit for the equipment(s) have been returned after job completion. SIC will
consult electrical supervisor and maintenance supervisor to verify job completion.
4. In case hard copy(s) of the work permit(s) issued are not available, SIC is to call electrical
supervisor or designate and carry out a joint survey of all equipment(s) that will be energized
by the breaker.
5. After verification, the lock can be cut after taking approval from MSO. Cutting of lock is to
be carried by electrician. Normal procedure(s) for carrying out the job are to be followed
and a hot work permit is to be issued.

10.7 Stored Chemical Energy LOTOTO


1. Line break and Equipment opening

1. It is expected that every line/system break (opening for repair) will be conducted in a planned
and controlled manner and will utilize written procedures from beginning through return of
the equipment to operation.
2. The opening of piping systems and vessels goes beyond the first break and must include all
breaks and disassembly/re-assembly where the potential exists to release trapped pockets of
hazardous material that may not have been cleared during preparation for a system/line break.
3. Opening cleared or uncleared lines or equipment by actions that may include, but are not
limited to;
• Breaking flanges.
• Removing one or more bolts from flanges.
• Opening valves to the atmosphere.
• Removing valve bonnets and non-return (i.e., check) valves.
• Turning spectacle plates (i.e., blanks).
• Breaking pipe joints.
• Removing slip plates (i.e., blanks), Blind flanges, plugs, and caps.
• Disconnecting tubing.
• Disconnecting loading and unloading process hoses.
• Penetrating a line by mechanical or other means.
• Opening inspection ports.
• Making subtle adjustments (e.g., replacing packing on a valve).

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2. Area Owner (Production) – Responsibilities

Area owners are responsible to perform the following tasks according to standard area
procedures or by procedures written specifically to address job tasks not encompassed by
standard area procedures.

a DE-ENERGIZING

• All pumps, turbines, etc., that generate pressure or vacuum in the line between isolation
points must be properly de-energized. Steam heated/traced pipelines must be properly
isolated / valves closed. De-energized equipment shall be locked/tagged/tried per applicable
procedures.

b ISOLATING THE PIPELINE

• Ensure, as necessary, to completely isolate the pipeline. Consideration must be given to any
potential for increasing pressure on the upstream side of valves during the period that work
is being done on the downstream side that might increase the probability of leaking through.
This aspect to be clearly defined & also covered in the relevant procedures / instructions to
the relevant personnel.

c FLUSHING, PURGING, SWEEPING, EVACUATING, ETC

• Perform as required to clear contents from lines, equipment, etc., and check for adequacy.
Type of chemicals (if any) used to flush a system must be taken into consideration when
determining the status before equipment handover to other work groups.
• Environmental concerns must be taken into consideration when disposing off chemicals. All
systems that are prepared for pipe and system breaks must be clear of hazardous material. If
the system is not flushed and cleared using a standard operating procedure, then a JSA should
be carried out & special procedure must be prepared and attached to this permit. Special
procedures should consider the following elements:

• Compressed Air Required


• N2 Purges
• System Venting
• Opening Drains
• Ventilation
• Spill Containment
• Valve Positions
• Pockets of uncleared material

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d CLEARING
• Every attempt shall be made to clear equipment and pipelines. Other accommodations may
be necessary before work proceeds.
• Every effort must be taken to ensure that flushing of the entire system is complete with
precautions taken to stroke or open automatic and manual valves to avoid any material being
trapped in the valve core or between the body and adjacent flange or blinds.
• Special consideration to be given for legs of acid / caustic circuits.

e VERIFYING

Verifying is to certify that the system is free of all hazardous materials. The following aspects of
the verification process should be given consideration.
• Pressure Readings
• Stroking valves
• Temperature readings, Laser Gun readings
• Weeping Drains & Vents,
• pH of material
• Air Analysis
• Gas Analysis
• Explosivity check
• Visual Inspection
3. Job Executor (Maintenance/ I&E/ Other) – Responsibilities

1. Knowing as required that the system has been cleared, flushed, and drained of any hazardous
material, including trapped pockets of material.
2. Locating the nearest safety shower before breaking into lines. The shower will be turned on
to verify that there is adequate flow. If the safety shower is farther than 50 feet or reaching
it requires a travel of more than 10 seconds and the job requires a protective suit, some
other source of flowing water shall be provided.
3. Never completely disconnect a screwed joint or remove all bolts from a flanged connection
until it has been confirmed that all the system pressure has been vented. On screwed
connections, loosen halfway (shake or pry connection) and check for trapped pressure or
liquid before taking apart.
4. On flanged connections, first loosen bolts on the opposite bottom side from the working
position, and then proceed to the near side and allow draining or venting.
5. Wearing the correct PPE and aware of what conditions or situations must be in place before
PPE may be relaxed or removed.
6. Job Turnover. It is important that both Operations and Maintenance personnel communicate
as to the status of the work at shift change as well as the return of the equipment at the
completion of the job.

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4. Shared responsibilities of Line Supervisors

1. Ensuring that employees know the procedures and instruct the employees about the
importance of following procedures.
2. Ensuring proper & positive isolation of electrical, process or any form of hazardous energy.
3. Specifying any additional protective equipment as warranted by individual job conditions.
4. It is important that Operations and Maintenance personnel, and Contractors, if involved,
communicate to oncoming shifts the status of the job, which would include isolation locations,
clearing verification method and status of equipment.

5. Lock out/ Tag out during Shutdowns / Incoming Shifts

1. During shutdowns / for incoming shifts, the following must be followed:


2. The Production Shift In-charge will make certain that the locks/tags are installed as per
lockout/tag out procedure until the job has been completed.
3. The key or keys for the safe lockout of the equipment or Process or Pipe will be passed on
from shift to shift, provided that during shift handover/takeover, the lockout system is
carefully reviewed and well understood by the Shift In-charge accepting the key or keys.
4. For “Interface employees”, either a new permit should be obtained at the end of the shift or
the permit may be extended. The name of Authorized Employee has to be mentioned on the
card copy while extending the work permit.
Note: Signature & & P. no of in- coming SIC is mandatory on tags at all local ON/Off
switches.

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10.8 Valve LOTOTO Specific Guidelines


1. Scope
• In continuation to the Line Break and Equipment Opening procedure it is expected that
there will be no point in time where potential stored energy is encountered.
• For this, electrical energy isolations and de-energizing is carried out as per already defined
guidelines.
• To further ensure zero accidental encounters to stored energy caused by Process Fluids,
there is a need to mechanically secure the isolation valves around equipment where
maintenance jobs are required before commencement of the job.
• The guidelines and protocol for Management of Lock Out / Tag Out of valves to meet the
above-mentioned purpose are defined below.

2. Application

The procedure will be applicable to all isolations required to do any job on below mentioned
services if there is any line/flange break involved.

Note: In-order to install a blind in line or to a flange, valve LOTO must be installed
before permit issuance for blind installation.

The locks and tags are required to be installed on process lines/services/ IVs including.

• VCM
• HCL
• EDC
• Ethylene
• Heavies
• PVC/ PVC Slurry
• Hypo
• Chlorine
• Chlorinated/ Depleted Brine
• HSD
• Aromatic 150
• Acid / Caustic
• Additives, reaction killers and other such substances
• All hydrocarbons
• Dosing Chemicals
• Feed/ Fuel gas,
• All liquid/gaseous Chlorine

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• Steam,
• BFW,
• Carcinogenic Services
• Catalysts (Liquid)
• Cryogenic Gases
• Water above 70 ⁰C or at 5 bar pressure
• Other process lines e.g. potable water, DW, Cooling water lines, Plant and instrument air
service etc. are to be properly isolated and tagged only.

The valve LOTO must be performed for all


associated isolation/points involved in the activity.
These includes the isolation valves (in closed
position), bleeders & drain valves (in open position).

3. Color and Number


Colored and numbered locks will be used. White color is selected to differentiate them from the
Locks which are used for isolating electrical energy. The numbering of the lock will be preceded
by the letter V, followed by the number 1, 2 and 3 and so on.

Operation

4. Designated Location

Placement of the numbered locks and keys along with the cabinets will be carried out inside field
offices/area cabins whichever is closer to the operating units. Likewise, electrical energy isolating
lock keys, spare set of keys will be maintained in UMO Office.
5. Record keeping

Area engineer will fill out the record file of LOTO (placed inside Field Office/ Area Cabins) with
his Name, Date, Time, Lock Number, Specific Unit, Description of the Job and Signature. Incase
job gets competed Lock Removal Date and Time is to be mentioned on the record file along with
the on-duty area engineer name and signature.
6. Length of chains

Initially the chains of two lengths 500 mm and 1000 mm will be used on all sort of valves, but it
will further be streamlined as experienced.

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7. Designated Locations

The chains will be placed on the hangers provided at different locations specified by looking at
the frequency of maintenance related activities.
8. Responsibilities

1. All area Assistant Engineers will be responsible for locking out the required valves in field,
tagging the valves with “Do Not Operate Tag”, maintaining the locks, keys & chains, and
record throughout their respective shifts.

2. All SIC/SEs will carry out daily checks for compliance to this procedure and management of
locks and keys.
3. Management Safety Audits carried out by Manager Operations, MSO and other MSA
Auditors will also cover this aspect during their routine audits.

Caution: The lock from any valve once installed, can ONLY be removed if the related
work permit is closed and the copies have been exchanged between both the
Operations and Maintenance parties.

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SECTION-11 PERSONAL PROTECTIVE EQUIPMENT


(PPE)
11.1 Principle
1. For each job/task where there is potential exposure to a hazard, personal protective
equipment shall be specified, available and used.

2. Following are the considerations:


• SERVICE: What the line contains. Example: "VCM / HCL"
• OPERATING PRESSURE: Normal operating pressure
• OPERATING TEMP: Normal operating temperature
• INDICATED PRESSURE: Pressure indicated before break
• INDICATED TEMP: Temperature indicated before break

3. Where fire Suits, Acid Suits or Respiratory Protection are required PPE, the area operator
must be present when initial breaks are made and until enough drains or openings are made
to ensure that the system is properly isolated.

4. Additionally, a standby person will be required. The standby person will wear the same level
and selection of PPE as that required for those performing the line break. As needed, the
Area Operator and the Standby person can be the same individual.

5. Note: Where positive means cannot be established to determine the temperature and
pressure of service where a line break occurs, the selection of PPE is based on normal
operating conditions not indicated.

6. We must assume the worst condition when selecting our PPE for the line break.

11.2 Relaxation / PPE Removal

1. Operations and Maintenance group must agree before starting work if one or more of these
conditions as outlined below can be met so that personal protective equipment can be
relaxed.

2. If a condition other than the four mentioned below is used to relax PPE, then a written
explanation must be prepared and attached to the permit.

3. Wearing of fire suits, acid suits, or any type of respirator or fresh air mask generally indicates
the highest potential for exposure to hazardous services and when they are worn, operations
must have a knowledge of the equipment standing by in case something happens that requires
immediate response on their part.

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4. Once the Operations SIC and Maintenance Supervisor agree that those conditions as outlined
in the permit have been met, then the level of PPE can be relaxed.

5. In general, one or more of the following conditions must exist to relax PPE:

a Pipe, piping component, or vessel can be seen through end to end, visual confirmation.
b Open ends have been positively sealed by devices such as flange blinds, and/or screw
caps/plugs.
c All piping, valves, vessels, and other components within the system to be worked on have
been opened to the atmosphere, have been thoroughly flushed or purged out, all drains,
vents, and low points drained of liquid, and verified free of hazardous material.
d Openings in pipe, piping component, or vessel verify that the material left has changed
temperature and/or consistency such that no hazards exist.

Note: Agreement must be made with Safety Manager/ MSO before relaxing PPEs where
hazardous service is involved.

11.3 The Unexpected

• When in the course of a job, conditions affecting safety, health, or the environment differ
from the expected (e.g. Drain valve plugged or line cannot be cleared) the job shall be re-
evaluated, and a new plan developed. In case of unusual conditions, the work should be
stopped.

• List any conditions found that made it necessary to stop work. Example: The line was found
to be pressurized.

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SECTION-12 WORK PERMIT TRAINING & AUDITING

1. All EPCL employees who are involved in Work Permit system will be provided training on
the procedure during first year of their joining the company.

2. Refresher training will be conducted after every three years.

3. All employees involved in Work Permit system will be required to qualify the test on Work
Permit procedure within three months of joining the Company.

4. Safety Section will maintain a record of all employees who have qualified the test. After
qualifying the work permit test, they will further be evaluated through interview/ skill
certification program.

5. No employee will issue/receive the Work Permit independently unless he/ she is declared as
wok permit certified by the HSE department for handling permits.

6. Any exceptions to this rule must be granted by Manufacturing HSE. For certain specified jobs,
contractors are eligible to handle work permits after qualifying EPCL Work Permit Test and
obtaining Manufacturing HSE’s approval.

7. The list of such qualified contractors must be always available in respective control rooms
and work permits should only be issued for the specified jobs.

12.1 Gas Testing

• Gas testing should be done only by employees who have been formally trained, tested, and
approved by management. Refresher training for these employees should be held on a regular
basis (at least once in a year) to maintain an acceptable level of proficiency.

• Site management should maintain up-to-date records of individuals qualified to make gas tests.
The list of qualified personnel should be displayed in the Control Room.

12.2 Confined Space Rescue Team

• There will be special emphasis on the training of rescue squad members on Confined Space
Entry Rescue.
• Normally, all emergency squad members will also work as rescue squad members and will
receive required training once a year.
• The Operations Manager may, however, nominate a person as rescue team member provided
he has received training on basic first-aid, CPR and rescue techniques.

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12.3 Scaffolding Certification

• All Maintenance, Project and I&E Supervisors will undergo training on scaffolding standards in
place at EPCL/Third party.
• Only those employees will be authorized to certify the scaffolding who have qualified the test
for scaffolding certification through 3rd party.
• For details, please refer to Site Safety Manual Section 12 - Scaffolding Guidelines

12.4 Work Permit Audit

• Routine audits of various parts of the Work Permit process should be conducted to ensure
compliance with the procedures and to see that the procedures in place are meeting the
needs of safe operations.
• The respective Manager Maintenance / Production / I&E / Project Engineering) should retain
duplicate or original copies of the closed Work Permits for at least one month from audit
point of view.
• Audit of Work Permits by third party will be conducted by Safety Section.

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SECTION-13 WORK PERMIT SKILL CERTIFICATION


13.1 PURPOSE
The purpose of this procedure is to ensure Work Permit Skill Certification Program at EPCL
plant site remains fully functional. Full compliance towards this important process and personnel
safety protocol will result safe handover, execution, and closure of all activities. This procedure
ensures site process & personal safety.

13.2 REQUIREMENT
All EPCL employees of manufacturing division & Contractor employees must be Work Permit
certified through this procedure for Work permit handling.

Following are major steps of employees Work Permit Certification Program-


• PSM Certification
• Work Permit study & training of the employee.
• Work Permit electronic test.
• Work Permit test for dummy run.
• Work Permit final interview of the individual for certification.
• Communication & Record.

13.3 PSM Certification


After an employee clears PSM Certification, only then he or she shall by eligible for Work
Permit Certification. For production department, please see section 10 of PSM -09
Training & development (Document # HSE / PSM / Level-II / 09).

13.4 Permit Certification for Non-Technical Employees

• For work permit certification, an employee must have PSM certification or a sound knowledge
of PSM elements.
• All non-technical staff i.e., Admin or supply chain employees who do not appear for PSM
certification need to clear tests of below mentioned PSM elements to get eligible for work
permit certification.
• By clearing below mentioned PSM elements followed by interviews, non-technical employees
will be able to handle permits other than LOTOTO, rigging, live circuits.

a PSM 11 - Incident Investigation


b PSM 15 - Procedure & Performance Standards
c PSM 16 - Management of Change - Facilities
d PSM 19 - Pre-Startup Safety
e PSM 22 - Emergency Preparedness and Contingency Planning

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13.5 Work Permit study & training of the employee


First employee will study the Work Permit Procedure. This will be followed by employee
discussion with Supervisor on Work Permit procedure.

13.6 Work Permit electronic test.


1. Employee will appear in Work Permit electronic test in Training Department.
2. If he obtains 95% or above score in this test he will be considered “Cleared”
3. If he obtains less than 95% marks in this test he will be considered “Failed”
4. “Failed” individuals can reappear in this test after 07 working days.

13.7 Work Permit test for dummy run

1. Training Officer/ Engineer will fill out the work permit certificated mentioning the score
obtained by the individual in work permit test.
2. “Cleared” individual will report to HSE Department.
3. “Cleared” individual’s dummy work permit test will be conducted by HSE Engineer.
4. HSE Engineer will ask the “Cleared” individual to fill a dummy work permit for a specific job.
5. This dummy work permits test has a maximum score of 5.
6. HSE Engineer will mark the score out of 5 for dummy work permit filling exercise.
7. Work permit electronic test & dummy work permit filling exercise scores will be totaled by
the HSE Engineer.
8. If the individual obtains 95% or above, he will be considered “Cleared”.
9. HSE Engineer will clear the certification of individual person in system as a proof of his
“Clearance” in Work Permit test.
10. If he obtains less than 95%, he will be considered “Failed”.
11. “Failed” individuals can reappear in test after 07 working days.

13.8 Work Permit final interview of the individual for


certification.

1. “Cleared” individual will appear in interview for final Work Permit Skill Certification.
2. Safety Manager/ Training Manager will conduct the final interview of “Cleared” individual for
Work permit skill certification.
3. Respective department Manager will raise a formal request to the Safety Manager/ training
Manager for a work permit interview date through e-mail/through LMS system after ensuring
that the individual being interviewed has sufficient knowledge on work permit protocols.
4. If individual clears the interview, Safety Manager/ Training Manager will clear the certification
in SAP LMS system
5. If the individual fails in interview he will reappear after 15 working days.
6. Record will be maintained in LMS.

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


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13.9 Work Permit Skill Certification Communication & Record


1. Training will issue an e-mail to respective department’s Manager stating that this employee
has cleared the Work Permit Skill Certification & can handle Work Permit independently.

2. Respective Manager will issue an e-mail to all interfaces stating that the said employee has
cleared the Work Permit Skill Certification & is now allowed to handle Work Permit
independently.

3. Permit certified people list will be readily available in LMS with training department.

4. If an individual is away from company for more than 6 months and rejoins the company, he/
she shall be exempted from Work Permit online testing. However, he/ she shall appear for
final interview.

5. If an individual is away from company for more than 1-year, complete re-certification to be
done including tests followed by interviews.

6. For permanent employee hiring (GMs and above) the online test regime shall not be
compulsory however they must appear for an interview with GM HSE to get certification.

7. Incase an individual clears interview through Training Manager, he shall ensure that HSE
department is adequately/ timely informed to update the Work Permit certified person list.

8. GTEs and TAEs may clear the work permit certification but they are not authorized to handle
work permit until job confirmation.

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


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SECTION-14 WORK PERMIT REVISION PROTOCOL

1. All the job at site must be executed following the permit guidelines mentioned in this
procedure.

2. Work Permit procedure is revised after every 3-year frequency. All the proposed changes
must be presented in MHSE and approved prior to incorporation in procedure during revision
phase.

3. Any changes in permit protocols can be implemented through site safety notices duly
approved by GM-HSE.

4. All issued site safety notices must be incorporated in procedure during revision phase.

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


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Revision: 05 Date Revised: 31st March 2021

SECTION-15 APPENDIX
15.1 Permit Waivers of TA-2020

1. General Work Permit

1. Enlisted DCS Engineers can authorize Cold work permits (except LOTOTOTO, SCD, first
line break, MOC & Hot) during the turnaround
2. Operations to Operations Work Permit (jobs under cold work, non-LOTOTOTO,
confined space etc.) and area entry/exit protocol waived off. Communication will be done
by production manager.
3. As per protocol LOTOTOTO and marked P&ID to be signed off by incoming SIC within
two hours after shift starts. (For all the jobs that are in continuity only)
4. Area will be declared ear-plug free after shutting down all machines.
5. Splash Google waived off in enlisted operating areas.
6. No LEL monitoring and permit required for vehicle stationed in process area in idle and off
condition.
7. Only one Work Permit will be taken for each plant’s vehicle activity. i.e. Crane, pay loaders
etc. While no permit will be required for folk lifters.
8. All work permits including Hot work and Vessel entry permits can be issued till 0900 hours
and 2100 hours, respectively.
9. Hot & Vessel entry Permits to be allowed for next shift extension for some specific enlisted
jobs.

2. Vessel entry waivers

1. Lifeline will not be mandatory for grade level vessel entries. (These Confined spaces on
grade level like VCM furnaces radiant sections / Oxy Reactor Spurger manway, Dryer Filter,
are enough open spaces for multiple entries)
2. Confined Space entry can be resumed after lunch/ dinner breaks on the same work permit
but after fresh O2/ LEL/Toxicity monitoring. (During S/D there would be number of Entries
in progress and not possible to issue fresh permits for all such jobs)
3. LEL and Oxygen monitoring can be done by Trade Apprentice/ TAE/ GTE, Certified Gas
Tester list to be shared with HSE & MSO prior to utilization.
4. 24V or less portable LED lights are to be allowed for Vessel Entry jobs.
5. Hazardous gas sampling through Lab is mandatory for 1st entry (every man way) only,
subsequent monitoring will be done through portable meter. In case of any complaint,
resampling will be done through lab.
6. LEL monitoring for all vessel entries will be done on 3 hours frequency.
7. One P&ID, Blind List and Rescue plan is valid for one column/ Tank/ Vessel, (For single or
multiple entries in a same vessel of column, P&ID marking and rescue plan will be displayed
so no need to display at multiple locations)

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


Document # HSE/ HSE - Safety – SSM - II - 008 Date Prepared: May 2014
Page 106 of 107
Revision: 05 Date Revised: 31st March 2021

8. For first entry in multiple manway vessel or column, separate permit will be issued for
different manways at one equipment mentioning man ways numbers where entry need to
be conducted. Later, one permit will be enough for all man ways
9. LEL and O2 monitoring from every manway is required

3. Hot work permit protocol:

1. LEL monitoring in TA will be on 3 hours monitoring regimes for all hot jobs (Expect special
jobs like VCM Sphere) whereas for LEL monitoring in Area 600 of EDC plant, the protocol
will be separately communicated to all relevant interfaces
2. After declaring an area Hydrocarbons or flammable material free, an email will be circulated
by Concerned GL after approval from General Manager Production and after that it will be
considered as Non-Classified and same protocol will be followed.
3. Hot Work permit with checklist can be authorized by Operations Shut down Coordinator
in addition to Manager Site Operations Initial must be mention at Work permit & checklist.
(As hot jobs are extensive to possible for MSO to approach all each hot jobs)
4. Hot work permit will be issued for opening of any explosion proof control panel / junction
box in case where area is not free of hydrocarbons.
5. Single Fire watchmen can be deputed for multiple jobs on same platform.
6. Fire extinguishers for TA hot jobs will be provided by HSE team to maintenance
department. In case of requirement of any extra extinguishers, area fire extinguishers can be
used by ensuring the certification tags on them.

4. Vehicle Entry and Photography:

1. After declaring complete HC Free plant by Concerned Unit Manager after approval from
Production GM, only single vehicle permit to be taken for crane in each plant and separate
cold permit to be taken for separate job. LEL sheet to be kept pasted on crane and must be
updated after 03hrs.
2. After declaring complete HC Free plant by Concerned Unit Manager after approval from
Production Manager, permit will be waived off for photography (without flash) in all
respective operating areas but shift in-charge must be informed prior to take any
photograph in area.
3. Photography on FGC/ GT/ FGC: There is no requirement of Photography permit after
mentioned machines shutdowns and NG isolations.

5. Electrical Equipment Certification

1. Grinders’ checklist must be filled and valid for 15 days. In addition, grinder certification tag
is mandatory.
2. 220V light will be installed inside culvert (located at FGC north-west side) along with
double ELCB protection.

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd


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Page 107 of 107
Revision: 05 Date Revised: 31st March 2021

3. Waiver is requested for using non-intrinsic Vacuum Cleaner & Chiller on Oxy reactor after
Electrical certification & double ELCB Protection.
6. Scaffolding

1. Scaffolding Certification validity duration to be extended from 7 days to 15 days. However,


in case of certified scaffolding adjustment, re-certification will be required.
2. All scaffolding structures below 15 feet (or single platforms till Piperack) will be certified by
EPCL URS certified scaffolders present on site whereas for certifications of scaffolding
structure at 15 feet or more will be certified by scaffolding specialists arranged by HSE.
3. Use of base plate in all scaffoldings are mandatory except ‘’single plate form scaffoldings of
less than 10 feet height on the concrete floor only.

7. Prohibited Acts:

1. Scaffolder can take support of pipe if he stands on a METALLIC pipe of diameter 3 inch and
above while hooking harness at a height above his head.
2. Standing on non-metallic piping is not allowed.
3. Standing on metallic piping of diameter 2.5 inch and below is not allowed.
4. Metallic piping should be visibly healthy without any severe corrosion flakes.
5. Standing on piping without hooking harness at a point above the head is not allowed.
6. Standing on Process piping at ground where this act is avoidable is not allowed.

Revised By: AH Reviewed By: SSHR/AR Approved By: MSd

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