Holcim Directive on OH & S

FATALITY PREVENTION ELEMENT # 6: CONFINED SPACE ENTRY

1. Basis
Holcim Group Occupational Health & Safety (OH & S) Policy, Annex 2 Management Handbook for Occupational Health & Safety of Holcim Ltd Chapter 4

2. Approval
This directive was approved by the Holcim Executive Committee on October 26, 2007

3. Validity
This directive will come into force on November 1, 2007

4. Replacement
This directive is new.

Fatality Prevention Element

Confined Space Entry

1.0 Context:
Many workers have died while undertaking work within confined spaces or while attempting to rescue fellow workers from confined spaces. As there are numerous confined spaces at sites operated by Holcim Group companies, the management of entry into, working within and exit from confined spaces is critical.

2.0 Purpose:
To specify the controls that must be put in place to ensure that entry of persons into a confined space is controlled, regulated and the risk is minimized. To also ensure that when persons are working within a confined space they are protected from the hazards associated with the confined space or those that may emerge in the confined space while undertaking the work.

3.0 Scope:
This element applies to all confined spaces on premises operated within a Holcim Group company and to any entry by a Holcim employee into a confined space at any other location.

4.0 Element Requirements 4.1 Hazard Identification Risk Assessment and Risk Control
A survey must be undertaken to identify all confined spaces and restricted spaces which are present at the operation. The survey must: Record each location, structure or facility considered to be a confined space. Describe the hazards that are present within the confined space. Confirm that signage is located at each access point specifying that a permit is required prior to entry into the confined space.

Accountable

Note: refer to the glossary of terms for an explanation of a confined space and a restricted space. A risk assessment of entry to each confined space must be undertaken and documented prior to the issuing of a confined space entry permit. The risk assessment must address as a minimum the following: Air quality - low oxygen level or high oxygen level, potential for atmospheric contaminants, flammable substances, requirements for regular monitoring. Potential for engulfment/burial. Potential for temperature extremes. Isolation procedures to control contaminants and other energy sources. Requirement for natural or forced/supplied ventilation. Requirement for respirators or breathing apparatus. Access/egress requirements. Development of rescue plans and provision of rescue equipment. The need for a standby person outside the confined space.

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Fatality Prevention Element

Confined Space Entry

In addition to the confined space entry permit, a safe work procedure task/job safety analysis of the activities to be undertaken while in the confined space must also be documented. This task analysis will address the following as a minimum: Proposed work activities. Equipment to be used. Energy sources to be introduced into the confined space. Potential for generation of contaminants which can be created through the method of work. Requirement for other safety equipment and PPE. Other hazards which may be present.

Note: Specific safe work procedures must be developed for activities that are more hazardous when carried out within a confined space. These activities typically are those that create additional hazards due to the type of work to be performed. Examples include: Falling materials/objects (working within silos, kilns, clinker cooler, crusher, hoppers) Hot work (welding, cutting, grinding) Chemical cleaning Steam cleaning Abrasive blasting (grit, bead, sand, garnet, copper slag etc)

All documentation, risk assessments and records relating to each confined space must be reviewed as follows: surveys : five years risk assessments : 12 months

The full requirements of this Fatality Prevention Element will apply once circumstances arise which require a restricted space to be treated as a confined space.

4.2 Selection, Training, Competency and Authorisation

The selection process shall ensure personnel required to operate in, or perform work within confined spaces meet defined criteria for medical fitness and health. The training and competency assessment system for working with confined spaces will ensure that: Training involves formal competency assessment by means of practical and theoretical examination. All training undertaken and results of competency assessments are recorded and records maintained

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Fatality Prevention Element

Confined Space Entry

The training for authorizing personnel to issue a confined space entry permit must include, but is not limited to: Instruction on the hazards of confined spaces; Instruction on the requirements contained in the confined space entry process; Roles and responsibilities of the confined space entry permit issuer; Familiarization with emergency response procedures, and Training in the operation of gas detection equipment.

The training program for all persons who are required to work in a confined space must include, but is not limited to: Instruction on the hazards of confined spaces; Instruction on the content and purpose of the confined space entry permit; Familiarity with the relevant safe working procedures; Understanding the emergency response procedures, and Role and responsibilities of the standby person.

Rescue personnel shall be specifically trained in relation to undertaking rescues from each confined space. Note: The standby person is not permitted to enter the confined space and undertake a rescue unless a back-up rescue person is also present and suitable equipment is available.

4.3 Communication and Awareness

Confined spaces must be identified and signs erected at the entry points indicating that a permit is required prior to entry. Such signs must be permanent in nature and be available in a suitable language/s. Awareness information and/or instructions must be provided on a regular basis to personnel who may perform work within a confined space. The following topics should be addressed: Definition of a confined space. Hazards presented by confined spaces. Permitting requirements for confined space entry. Confined space entry equipment and procedures.

Changes to a confined space or the commissioning of structures/facilities which have confined spaces must be: Documented or existing documents updated; Incorporated into rescue plans; Signposted at the access points denoting a confined space permit is required prior to entry; and Records of such communication must be maintained.

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Fatality Prevention Element

Confined Space Entry

4.4 Design, Purchase, Fabrication, Installation and Commissioning
When designing new plant or purchasing new plant and equipment, a review should be undertaken to identify potential confined spaces and attempt to eliminate them from the design. Purchasing specifications must be developed for all confined space entry equipment including: Ventilation equipment. Monitoring equipment (air quality or gas detection). Breathing apparatus. Rescue equipment.

Extraction systems for use in confined spaces must be fit for purpose and any materials used must be capable of withstanding the circumstances likely to be encountered in the confined space, e.g. extremes of temperature, corrosive materials.

4.5 Work Method and Condition Control

Entry into a confined space is only permitted after written authorization in the form of a confined space entry permit. The confined space entry permit must record the following: Risk assessment of work to be undertaken in the confined space. Identification of isolations required before entry. Recording of initial air quality - gas analysis and recommendations for ongoing monitoring. List of equipment permitted within the confined space including safety equipment required. Name of standby person (sentry) who will remain outside the confined space. Record of persons within the confined space at any particular time.

Confined space permits will be valid for a maximum period of 7 days. A copy of the permit must be retained on file. Note: Atmospheric testing and monitoring in the confined space shall be carried out consistent with the hazards identified and the risk assessment. Safe levels for entry shall be oxygen 19.5 % to 23.5 %, flammable gas less than 5% of lower explosive limit, other contaminant personal exposure to be less than 50% of the occupational exposure level. Ventilation and lighting must be adequate for the task being performed within the confined space. Specific approval will be required to enter a confined space without testing the atmosphere in the confined space.

4.6 Maintenance
Gas detection equipment must be calibrated and maintained in accordance with manufacturers specifications. Gas testing equipment must be tested prior to analysis of the air within the confined space. Where air is supplied to personnel within the confined space by means of a compressor, an analysis of air quality must be undertaken prior to entry into the confined space.
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Fatality Prevention Element

Confined Space Entry

All protection, rescue, ventilation and other safety equipment used for confined space entry must be included in a maintenance program which includes: Schedules for conducting maintenance or calibrations; Requirements that maintenance manufacturers specifications; is undertaken in accordance with

The use of manufacturers or approved parts; and The recording of all maintenance work conducted.

4.7 Emergency Controls

A specific rescue plan for each type of confined space must be in place and suitable rescue equipment must be available before any entry to confined spaces takes place. Based on the rescue plans the types of emergency response scenarios likely to be encountered need to be documented and suitable emergency response equipment must be made available for each type of foreseeable emergency scenario. Emergency response personnel must be trained in confined space rescue and undertake drills directed at rescues from specific confined spaces.

4.8 Monitoring, Inspections and Audits

Annual audits must be performed to verify the quality and effectiveness of the requirements set out in this element and for compliance with applicable legislation. Inspection of all equipment used for entry to or monitoring confined spaces must be maintained in accordance with manufacturers recommendations and results recorded. Task/Safety Observations must be performed for the purpose of measuring compliance in regard of: Permit issuing procedures. Gas testing procedures. Relevant safe working procedures. Status of the rescue plan and equipment.

4.9 Reporting, Assessment and Corrective Actions

Processes must be in place for the reporting, assessment, and correction of hazards identified with confined space entry equipment or procedures and must address: Actions required to stand down unsafe equipment or stop work; and The recording of actions taken to correct the hazard or defect.

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Fatality Prevention Element

Confined Space Entry

5.0 Glossary of Terms

Accountable

The person designated to ensure that the assigned requirement is implemented. This person is held answerable for the level of compliance against the stated requirement. Granted permission by the responsible Department Manager of an operation or person nominated by such responsible Manager to carry out specific tasks e.g. Issue a Confined Space Permit. A person having a combination of training, education, experience, acquired knowledge and skills which enables them to perform specified tasks to a predetermined quality, which may be assessed against defined criteria.

Authorized

Competent Person

Confined Space

A confined space is an enclosed or partially enclosed space that is under atmospheric pressure during occupancy and is not intended or designed primarily as a place of work and which potentially (a) has an atmosphere which contains harmful levels of contaminant or temperature extremes; or has an oxygen deficiency or excess; or can cause engulfment. and (b) has restricted means for entry and exit. Common examples of confined spaces: Silo - Raw Material and Cement Storage tanks, vats, chambers, Pits, sumps, vessels, accumulators, receivers Vehicles - bulk carrier tanks, barrels on RMX trucks, Slew ring compartments on excavators Equipment - crusher and mill assemblies, apron feeders, cyclones, kilns clinker coolers, RMX mixer compartments,

Contaminant

Any dust, fume, mist, vapour, gas or other substance in liquid or solid form, the presence of which may be harmful to health or safety. A firm or person employed under a contract to provide services to Holcim as distinct from having a contract of employment with a Holcim Group company. When a persons head, ie, the breathing zone, or upper body is within the boundary of the confined space.

Contractor Entry to Confined Space

Note: Inserting an arm for the purpose of atmospheric testing is not considered an entry to a confined space.

Must / Shall Potential to cause a Fatality / Risk of a fatality

Must / shall is to be interpreted as mandatory. A hazard that has been identified, that if not properly controlled, may contribute to a fatal incident. This can be derived from previous fatal incident experience and/or have been identified by means of a risk assessment as having the potential to cause a fatal injury.
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Fatality Prevention Element

Confined Space Entry

Records
A health & safety record is a record of evidence. Once they are generated, records cannot be changed or updated. Records provide evidence of the status of the OHS Managements system at any given time. It is essential that all Holcim Group companies have an effective records management system. As a minimum, records need to be held for: Risk assessments (e.g. studies, surveys, risk assessments etc.); Health & safety training; Calibration and maintenance of monitoring equipment; Incidents, hazard reports, follow up actions; Inspections (pre-operation, equipment, pre-commissioning) Task/safety observations Supplier and contractor information; and Health & safety audits.

Note: records are not subject to government document requests without authorisation by Holcim legal counsel. Records (including permits, risk assessments, monitoring-, auditing- and related documents) shall be centrally stored for at least 7 years or any longer period if required by law. Training records shall be retained for a minimum of 12 months after the completion of the relevant employees term of employment. For further information relating to the management of records refer to the Holcim OHS Pyramid Element- Information and Reporting.

Restricted Space

A restricted space is defined as a structure which is not classified as a confined space as it is not a fully or partially enclosed structure. However, if activities are undertaken within a structure which has the potential to affect air quality then it must be treated as a confined space. Examples of this situation include but are not limited too: Painting or welding within a hopper or chute, Operating equipment which has an internal combustion engine within an excavation or structure which relies on natural ventilation.

Risk Assessment Standby Person (Sentry) Ventilation

A risk assessment is the estimation of the level of risk associated with and identified hazard. Risk is expressed in the terms of consequence and likelihood. A person stationed outside the confined space for the purposes of monitoring access and egress from the confined space and raising the alarm in the event of an emergency. A natural or mechanical means of providing a workplace with air that is free from atmospheric contaminants, such as dust, fumes, mist, vapours and gases, as well as controlled temperature extremes. Ventilation can be a positive flow of air to the workplace or an extraction device that removes potential airborne contaminants from the immediate work area.

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