Individual Unit Function: Safety Procedure No.: SOP-0138 Page: 1 of 10

Transcription

1 Procedure No.: SOP-0138 Page: 1 of PURPOSE To ensure work is performed in a safe manner by: Ensuring clear communications about the work to be accomplished. Providing approval from the equipment owners. Identifying and communicating hazards related to the identified task. Providing protective measures to address the identified hazards. Providing specific communications on lockout/tagout of hazardous energy sources. Determining other permit requirements (Confined Space Permit, Excavation Permit, etc.) Safe Work Permits are an essential aid to make sure that tasks with special risks can be planned and carried out safely. Because many tasks are performed by workers other than those who operate the plant, clear and formal agreements are necessary. Prior to the start of a particular work activity, a risk assessment (or a review of the hazards) must be carried out. 2. DEFINITIONS Authorization Log (AL) A form used to authorize activities provided by personnel providing a service to the Operating/Owning Department. Work activities examples: Visitors Janitorial Service Contractors An individual or group of individuals who are retained to perform work on behalf of BASF, but are not directly supervised by BASF employee. (Note: In this procedure, a Contractor also means subcontractor.) Contracted Employee An individual or group of individuals, not employed by BASF, for whom BASF provides direct supervision in their day-to-day activities and direction as to how an activity is to be performed. Operating/ Owning Department The BASF unit or department that is responsible for the daily operation of the process, area or facility where work is being conducted.

2 Procedure No.: SOP-0138 Page: 2 of 10 Operating/Owning Supervision Each area will define the appropriate level to serve in this capacity. Trained and qualified personnel such as, supervisors, shift leaders, lead person, project engineer, crew leaders, etc., for the affected departments/unit. Permit Issuer Personnel that have been trained, qualified and authorized to issue permits on behalf of the department/unit that owns the equipment on which the permit activity is conducted. When Owning / Operating Department personnel perform work requiring a SWP, review by another qualified operations team member is required. (You can not permit yourself). Permit Acceptor Person responsible for obtaining approval to do work. Safe Work Permit (SWP) A form that provides written authorization to perform work that describes tasks, associated hazards, and appropriate control measures. Minor Activities These are tasks that have very low risk and routine. Examples are: Visitor walkthroughs Visual inspections Deliveries Copy machine repair Etc. Service / Maintenance / Contractor Work Work performed on equipment or at facilities to repair, service, maintain, construct, renovate, modify, load or unload, deliver, install, or beautify. 4-eyes Principle Is a rule that emphasizes 2 people are better than one. The use of 2 or more individuals (equipment owner(s) and individual(s) performing the work) to assess tasks in order to ensure that all hazards are identified and eliminated/controlled through safe work practices, PPE, communication/awareness, etc.. In addition, it is intended to develop shared worker safety accountability between the equipment owners and the individual(s) performing the work. GFCI

3 Procedure No.: SOP-0138 Page: 3 of 10 Ground Fault Circuit Interrupter-A device used to measure low levels of current to ground (below human injury potential) and trip if levels exceeded. NORM Low concentrations of Naturally Occurring Radioactive Material (NORM) are present on the surface of certain process equipment at the MIDGA facility. This material appears as a scale, which accumulates on the surface of the equipment and is detectable with radiation survey instrumentation. (Examples of equipment where NORM is present includes rotary vacuum filters, vacuum filter cloths, vacuum filter backing pads, and plastic or metal piping associated with these filters, filtrate pumps, impellers, piping used to transfer slurry from bleaching, and ductwork from calciner scrubber exhaust. Working with NORM materials may require special precautions such as direct ventilation, Dust mask, and gloves. Refer to SOP-0121 for further information.) Controlled Area A process, facility, building, operation, warehouse, or other area where BASF provides supervisory and management responsibility. Safe Operating Procedures (SOP) Written step by step instructions that describe how to carry out specific tasks. These procedures can be in different forms such as: Task Job Analysis (TJA), Job Safety Analysis (JSA), Work Job Instructions (WJI), etc. and must specify required Personal Protective Equipment (PPE) and when the PPE must be donned. Refer to BC for requirements for written operating procedures. 3. SCOPE This procedure applies to any job performed by Contractor employees, Contracted Employees, or BASF Employees that is initiated by the Work Notification System, capital project, or if the job requires other permitting. 4. PROCEDURE 4.1 General The Permit is valid as long as the Permit Acceptor remains on the work crew and job that the permit is issued for.

4 Procedure No.: SOP-0138 Page: 4 of 10 Managing tasks with hazards must be planned and carried out safely. This is accomplished by assessing all tasks other than routine operations which are covered by safe operating procedures. Task with special hazards (such as confined space entry, hot work, line breaking, and excavations) at facilities shall be authorized by use of a Safe Work Permit. Note that other permits may be required as part of this process. 4.2 Minor Activities Task for Minor Activities can be authorized by the use of a Safe Work Permit or Authorization Log. (Sign in Sheet). The log shall have a description of work, sign in time, sign out time, name of person conducting work, number of workers on the crew, name of person approving work, and an emergency contact phone number for the company. Personnel conducting work must sign out when leaving. This will ensure the ability to account for personnel during emergencies. Midga Minor Activities that are Authorization Log tasks: Janitorial Service Office Equipment Services Vending Machine Service Fire Systems Inspections Fuel and Chemical Deliveries Truck Pickups from shipping areas Railroad Switch crew leader Vendor deliveries not requiring other procedures such as Fall Protection, Barricading, Rigging, etc.(pallet deliveries, small parts, etc.). Lamp or lighting work performed by BASF personnel that does not require fall protection or other permitting. 4.3 Visitors Visitation to office areas and deliveries (and other similar types of tasks) to nonprocess or non-manufacturing areas may be controlled by methods other than an Authorization Log or SWP. These areas for MidGa Operations are: McIntyre Main Storeroom McIntyre Main Office Gordon Main Office All Plant and Mill Offices Main Lab, Plant and Mill labs Break buildings (hot houses)

5 Procedure No.: SOP-0138 Page: 5 of 10 Plant Tours Each area should establish controls for their individual situation such as designating certain entrances to be used that allow monitoring of visitation. 4.4 When Required A Safe Work Permit shall be issued by the Operating/Owning Department for the following work: 1. Any job performed by Contractor or Contracted Employees. 2. Any job performed by BASF Employees that is initiated by the Work Notification System unless the job meets the exemption criteria below. 3. Jobs requiring other permitting, (Line Break, Hot Work, Confined Space, Excavation). 4. Work involving Lock, Tag, Try of Hazardous Energy Sources. (Note: Safe Work Permitting may not be required provided the job meets the criteria for exemption below and control of hazardous energy sources is covered by equipment specific lock out procedures.) 5. Work involving potential chemical exposure. 6. Capital projects. For a job to be exempted from the Safe Work Permit it must be: Routine in nature and non-intrusive. Performed by BASF employees. Performed by trained personnel where detailed procedures have been developed. The procedures must have been developed based upon a hazard analysis, (JSA, JHA, etc), with step-by-step instructions, and must specify required Personal Protective Equipment (PPE). Approved by the area Production Superintendent. Approved by the area Maintenance Superintendent. Approved by a member of site EHS Department. These tasks require that a BASF Service Authorization Log, be maintained by the Owning/Operating Department in the area in which the work will occur. The Servicing Department will sign in before beginning work and sign out when the job is complete as a means of Communication. When BASF Qualified Electricians are performing work inside electrical panels such as programming changes, testing, PM, or repair type work, they are considered the Owner and no Safe Work Permit is required. This exemption requires the electrician to use yellow and/or red locks when appropriate.

6 Procedure No.: SOP-0138 Page: 6 of 10 Testing and troubleshooting outside of electrical panels is also included in this exemption however, when the job transitions into repair type work outside of the electrical panels, a Safe Work Permit is required and the Operator becomes the Owner again. (Note: At this point, all electrical panels must be closed to allow the Operator to enter the arc flash radius to hang the yellow Owner/Operator lock. If this is not possible, the Operator must comply with all 70E PPE requirements.) When BASF personnel conduct repair work on lamps and lighting, a Safe Work Permit is not required unless the job requires fall protection or other permitting such as for a confined space. The intent to do the work will be communicated to the operator using the Service Authorization Log. Service / Maintenance / Contractor work for the purposes of this standard is normally considered separate from Owning/Operating Department personnel who operate the equipment. When Owning / Operating Department personnel perform maintenance work, Safe Work Permits shall have a second level of review by another qualified team member. 4.5 Safe Work Permit Use Where work processes only have one assigned person on site to operate a process, SOPs must be used where a risk analysis have proven the maintenance work safe for one person. If a formal risk analysis has not been performed and reviewed ensuring the task can be completed safely, a team maintenance (2 or more) approach will be used. A (1) person task must also meet MSHA regulation criteria addressing requirements for working alone. 4.6 Permit Issuer: Permit Issuer shall meet with the Permit Acceptor initially at the specific location where work will take place to review all pertinent sections of the permit. Hazards identified and precautions to be taken shall be listed on the permit. All permits will be in duplicate form. One will stay with the Permit Issuer and the other copy will either be posted at the work site, or with one of the workers at the work site. When Service is required and no Owning/Operating Department personnel are available, such as at the mines/plants on weekends or down days, responsibility for all permitting can be transferred to the Service Department provided the Service Department is not a Contractor.

7 Procedure No.: SOP-0138 Page: 7 of 10 The following circumstances must be met in order to consider such individuals as Operating/Owning Department personnel: 1. They must be trained and qualified to perform the subject activities. 2. They must have a level of knowledge and experience with the operation/process (equipment, hazards, and controls) that is equal to any existing Operating/Owning Department personnel and a minimum of one year s experience in the work area. 3. They (job positions) are specifically authorized individually on a list approved by the Site Manager and maintained by the production area Superintendent as a member of the Operating/Owning Department for the specific tasks they perform under the exemption. This activity will be coordinated with the owning/operating department and the service department prior to shutdown. The permitting will be completed under the direction of the servicing department Supervisor. 4.7 Permit Acceptor: Must sign the permit to acknowledge and agree to the conditions on the permit. Has the responsibility to inform other workers working under the permit about the hazards of the job and the requirements of the permit. Must not transfer the permit to other personnel or shifts, unless the permit is revalidated from the Permit Issuer. Shall conduct or witness necessary monitoring, (such as air quality testing for confined space entry), as close as possible to the time that work will begin. Testing shall be repeated by the Permit Acceptor if work doesn t begin within 2 hours. Repeat testing shall be done shall be done by the Permit Acceptor: At the beginning of each shift. If there is a work stoppage for 4 hrs. Anytime a confined space has been vacated. If any conditions change that are listed on the permit, then the Permit Acceptor must communicate the changes to the Permit Issuer.

8 Procedure No.: SOP-0138 Page: 8 of 10 By signing the permit, the Permit Acceptor has verified the workers are trained to use equipment and PPE necessary for the job. Permit Acceptor must return the permit at completion of work or shift to an authorized permit issuer in the unit/department where issued and communicate any problems encountered or left in the workplace. 4.8 Contractor Safety Orientation Contractor employees must be given an orientation before allowed to conduct work on BASF property. Reference BASF Corporate Procedure BC Contractor Selection, Oversight and Safety. This orientation must include: General Safety Requirements. Obtaining approval to do work (Authorization Log). Emergency procedures. Entry and Exit requirements for the site. Requirements for Safe Work permits, including Hot Work, Line Breaking, Confined Spaces, and Lockout/Tagout. Requirement for obtaining permission to work and responsibilities of the Permit Acceptor. Hazard Communication (GHS) information locations. Training or orientation from other regulatory requirements (e.g. MSHA, DOT, etc.) 4.9 Safe Work Permit Review and Retention Safe work permits must be retained and reviewed at minimum of every 12 months. The BASF approved alternative; reviews may be conducted and documented more often, but permits must be retained for at least current month plus one. If more frequent reviews occur, required summary documenting the reviews must be kept for 12 months. Review of Safe Work Permits must entail: - A comparison of the site procedure to the corporate procedure requirements. - A review of incident reports involving Safe Work Permitting issues. - Field audit of work in progress. - Interviews with Permit Issuers, persons performing work, and other affected employees, including Contractor Employee (s) where applicable, to ensure they understand their roles and responsibilities. - Audit (a sample) of Safe Work Permits completed by different persons to verify completeness and accuracy.

9 Procedure No.: SOP-0138 Page: 9 of 10 - The review shall be documented. For an example, see the Safe Work Practices Management Review Checklist. * 2018 MidGa Permit Modification formal review and update to site permitting has been completed. Roll out for combined permit will be complete by year end (2018). The same review options will occur to support compliance with Responsible Care and BASF permit guidelines Training and Qualification for BASF employees Persons qualified to issue Safe Work Permits for MidGA operations shall be one of the following: Frontline Supervisor, Area Leader, Manager, Engineer, Designer or their designee. Qualified Operator(s) for the area issuing the permit. Note: Newly hired employees within the first 120 days of employment will require a second signature by a person qualified to issue permits as outlined above. Each unit/department must specify/confirm the following: Knowledge of applicable site safety and health work procedures. The minimum amount of unit/department experience. Refresher training or demonstration of competency every 3 years. Documentation of training, including: each employee s name, date of training. Training content, and means to verify employee proficiency. Corrective Action whenever deviations or inadequacies are found in the SWP program. Documentation of approved personnel trained and qualified to authorize work. 5. RESPONSIBILITIES 5.1 Site Manager / Director / Regional Business Unit Leader The management of each facility has the primary responsibility for implementation of this procedure. 5.2 EHS Specialist The EHS Specialist will complete the necessary reviews set within the Safe Work Procedure.

10 Procedure No.: SOP-0138 Page: 10 of OSIH CoE Manager The OSIH CoE Manager has the primary responsibility for the initiation, reissuance, administration, and/or interpretation of this procedure. 6 RELATED DOCUMENTS FO-0138 Safe Work Permit Form FO-0138A Service Authorization Log Section Revision Revised By Date Revised 4.6 Added language to conform to WJK 1/26/10 corporate procedure. 4.2 Added bulb changes to minor work WJK 11/29/ Added exclusion for BASF WJK 11/29/10 electricians doing work inside electrical panels All SOP Review EM 8/11/ Update EHS Response KH 12/15/14 All SOP Review DM 08/08/16 All SOP Review Update DM 11/15/16 Documentum All SOP Review KMH / DM 10/30/ Clarified language on document retention to reflect what is on the permit. DLA 6/11/18