KARBALA REFINERY (KR) INTEGRAED MANAGEMENT SYSTEM

Confined Space Entry

KR-HSE-006-24

Ian Fletcher
 KARBALA REFINERY CONFINED SPACE ENTRY PROCEDURE

Table of Contents
1 Introduction ............................................................................................................................. 2
2 Purpose .................................................................................................................................... 3
3 Scope ........................................................................................................................................ 3
4 TERMS, abbreviations .............................................................................................................. 4
5 Distribution .............................................................................................................................. 5
6 References ............................................................................................................................... 5
7 CONFINED SPACE DEFINITION ................................................................................................. 6
8 HAZARDS and riskS................................................................................................................... 7
9 LIFESAVING RULES. .................................................................................................................. 8
10 Confined space entry steps ...................................................................................................... 9
11 CONFINED SPACE OXYGEN LEVELS ........................................................................................10
12 Low oxygen levels dangers. ...................................................................................................11
12.1 OXYGEN ENRICHMENT ................................................................................................. 12
12.2 FLAMMABLE ATMOSPHERES .......................................................................................... 12
13 TOXIC HAZARDOUS ATMOSPHERES .......................................................................................13
14 SAFE CLEARANCE MEASUREMENT.........................................................................................14
14.1 FUNCTION TESTS AND CALIBRATION ............................................................................. 14
14.2 REPRESENTATIVE ATMOSPHERIC MEASURING POINTS. .................................................. 15
15 GAS DETECTING .....................................................................................................................16
15.1 HOW TO DETERMINE WHETHER A GAS IS HEAVIER OR LIGHTER THAN AIR? ..................... 16
16 GAS DETECTING .....................................................................................................................17
17 GAS TESTING ..........................................................................................................................18
18 VENTILATION..........................................................................................................................19
19 Equipment ..............................................................................................................................21
20 RESPIRATORY PROTECTIVE EQUIPMENT (RPE) ......................................................................23
20.1 PROTECTION FACTORS ................................................................................................. 23
21 LEAKAGE FACTORS of respirators. .........................................................................................25
22 Protective suits. .....................................................................................................................26
23 FIVE STEPS TO FIND THE RIGHT SUIT protection ...................................................................27
24 UNDERSTANDING CHEMICAL PROTECTION...........................................................................28
24.1 WHAT ACCESSORIES DO I NEED FOR CHEMICAL PROTECTION? ....................................... 28

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1 INTRODUCTION
This confined space entry procedure (CFS) provides essential guidance on how the Karbala
Refinery(K.R.) shall safely control confined space entries at the Karbala Refinery (K.R.) and all its
off-site locations. It is intended to provide a structure to demonstrate K.R.'s top-tier
management commitment to health, safety, and environmental controls on the Refinery and
off-site locations.

Work in confined spaces is still one of the leading causes of workplace fatalities Worldwide.
Confined space entries are classified as high-risk activities that shall be controlled.

This Refinery manufactures and stores large quantities of hazardous substances, including
flammable and toxic substances, so the potential for severe incidents in CFS is always evident
when a worker has to enter a confined space.

The risks of an incident will be high without suitable practical control measures that reduce the
risk to as low as reasonably practicable (ALARP). It is a mandatory Refinery requirement that any
entry into a confined space shall follow this procedure.

In this document, the following verbal forms are used;

a) "Shall" indicates a requirement;

b) "Should" indicates a recommendation;

c) "May" indicates a permission;

d) "Can" indicates a possibility or a capability.

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2 PURPOSE
The purpose of the procedure is to establish the practical requirements for safe entries into
and work in places in the Refinery that are confined spaces.
The objective of this CFS procedure is to:
a) Prevent employees/workers from severe harm or death

b) Implementing suitable control measures to work safely in confined spaces

c) To provide clear guidance on how to plan for CFS entries

d) Providing details on CFS entry training requirements

e) Ensure arrangements are in place in case of an emergency involving CFS.

In this procedure, what a confined space is in the Karbala Refinery will be defined, and the
different existing categories of confined spaces will be established, identifying the risks and
safety requirements to consider to be able to work safely in a confined space.

3 SCOPE
This procedure applies to all persons associated with preparing and using work permits,
entering CFS, monitoring and supervising work in CFS, or providing emergency rescue for
confined spaces.

This procedure applies to all people and CFS activities carried out at the Karbala Refinery
and Company-owned property and land, which falls within the definition of work that
requires a general work permit as specified in this procedure.

The scope of this procedure applies to all employees, workers, contractors, visitors, and
anyone engaged in non-routine work on any K.R. facility. When entering the refinery facilities,
everyone is subject to mandatory following of the HSE arrangements.

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4 TERMS, ABBREVIATIONS Table. 1

Abbreviation What it means

ALARP As Low As Reasonably Practicable
APF Assigned Protection Factor
APR Air Purifying Respirator
CFS Confined Space
COSHH Control Of Substances Hazardous Health
CO2 Carbon Dioxide
CPR Cardiopulmonary Resucitation
E.I Energy Institute
E.R.T. Emergency Response Team
H.S.E. Health Safety Environment
IOGP International Oil Gas Producers
IDLH Immediately Dangerous to Life or Health
ISO International Standards Organisation
K.R. Karbala Refinery
LEL Lower Explosive Limit
LEV Local Exhaust Ventilation
LOTO Lock Out Tag Out

NIOSH National Institute for Occupational Safety & Health

O2 Oxygen
OEL Occupational Exposure Limit
PPM Parts Per Million
P.T.W. Permit To Work

RAMS Risk Assessment Method Statement.

R.A.C.I Responsible, Accountable, Consulted Informed
SCBA Self Contained Breathing Apparatus
SMS Safety Management System
STEL Short-Term Exposure Limit
SIMOPs Simultaneous Operations.
SQEP Suitably Qualified, Experienced Personnel

S.W.C. Start Work Checklist.

T.R.A. Task Risk Assessment.
UEL Upper Exposure Limit

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5 DISTRIBUTION

 Karbala Refinery (K.R.) Employees / Workers

 K.R. – Contractor and Sub-Contractors

 KR – Suppliers and Vendors

 Karbala Civil Defence (K.C.D.)

 State Company Oil Projects (SCOP)

 Ministry of Oil.

6 REFERENCES

̶ K.R. - H.S.E. Policy

̶ K.R. - H.S.E. Manual

̶ KR - Training and Competency Assurance Procedure

̶ K.R.- Incident Investigation Procedure

̶ K.R.- Lifesaving Rules Procedure

̶ K.R.- PPE Procedure

̶ K.R.- Permit To Work Procedure

̶ K.R. – Stored Energy Procedure

̶ K.R. – Control of Ignition Sources and Hot Works

̶ K.R. – Working at Height Procedure

̶ ISO 45001 Occupational Health and Safety

̶ ISO 3100 Risk Management

̶ EN 12021 Standard for Compressed Breathing Air

̶ EN 529 Standard for Compressed Breathing Air Apparatus

̶ ANSI 2117.1 Confined Space Entry Standard.

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7 CONFINED SPACE DEFINITION

A confined space is an area that is defined by at least one of the following parameters (but not
limited to):
a. Any space that is not designed for continued human occupancy but is large enough to
enter to perform work.
b. It has an internal configuration such that someone could be trapped or suffocated.
c. Any space that has limited means of access and egress
d. Has material that could be released or engulf someone entering the space
e. Any space with inadequate or restricted natural ventilation and the possibility of
lack/excess oxygen or accumulation of flammable and toxic vapors/gases exists
(including drains deeper than 1.2 meters deep).
f. Contains an identified health or safety hazard
g. May have changes in the workplace atmosphere.

A confined space could be enclosed or partially enclosed, either above or below the ground or at
ground level, where entry is physically possible.
Typical examples of confined spaces applicable to a Refinery are, but not limited to:
o Process Vessels,
o Process Exchangers,
o Process Columns and Column Skirts,
o Pipes,
o Ducts,
o Tanks,
o CO2 Compartments,
o Underground Pits,
o Cellars (in the PIBs)
o Sewage Pits,
o Silos,
o Drains and drain sumps,
o Deep Excavations >1.3m,
o Ceiling and floor voids,
o Any place that Task Risk Assessment identifies as a confined space.

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8 HAZARDS AND RISKS

Accidents in confined spaces(CFS), why do they happen? A confined space is among the
potentially most dangerous workplaces, and CFS entry presents many risks and challenges.
Despite the safety awareness of the dangers, too many incidents still happen Worldwide,
predominantly asphyxiation and exposure to hazardous substances or traumatic fall injuries, not
following the procedure or task risk assessment (TRA), to name just a few.
Confined space hazards may have reasonably foreseeable specified risks to workers of:
 Entrapment, lack of light
 Engulfment/drowning by liquids
 Asphyxiation, oxygen deficiency/enrichment (<19.5% / >23.5%)
 Lack of light and poor quality air, or toxic air, Hydrocarbons, Nitrogen, H2S
 Particulate, hazardous dust
 Fire or explosion, temperature extremes, ignition sources not controlled
 Loss of consciousness, chemical residues
 Simultaneous Operations (SIMOPS)
 Electrocution, lack of energy isolation
 Slips and trips and falls from height
 Competency of people entering the CFS, the supervision, and ERT.

When working in confined spaces, safety always comes first. Regarding the question of what
causes a CFS incident, let us look at that now. In a NIOSH survey of 100 fatality-type incidents,
we can learn some valuable lessons for Karbala Refinery's health and safety.
Here are some of the critical findings of the NIOSH investigations of confined space incidents:

 85% of the time, a SUPERVISOR was present.

 29% of the dead were SUPERVISORS.
 31% had WRITTEN Confined Space Entry PROCEDURES.
 0% used the WRITTEN PROCEDURES.
 15% had Confined Space TRAINING.
 0% had a RESCUE PLAN.
 60% of "WOULD-BE" RESCUERS died.
 95% were AUTHORIZED by supervision.
 0% of the spaces were TESTED before entry.
 0% were VENTILATED.
Out of 100 deaths that were investigated, the main reasons the workers entered the confined
space were to perform their planned work functions of routine maintenance, repairs, and
inspections of the confined space. All these incidents could have been prevented if the IOGP/EI -
Lifesaving Rules were followed and fully implemented.

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9 LIFESAVING RULES.

The International Oil Gas Producers (IOGP) / Energy Institute (EI) Oil and Gas Life Saving Rules
are Mandatory for all works on the Karbala Refinery. The following pertinent lifesaving rules
shall be followed 100% to prevent incidents involving confined space entries at the Refinery.

All the nine lifesaving rules are included in the appendices.

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10 CONFINED SPACE ENTRY STEPS

# STEP BY WHO
Walk down the area where the CFS is. Hazards are → Performing Authority (PA)
1 identified and noted. Isolations are identified and → Issuing Authority (Ops Supervisor)
marked up in P&ID. RAMS/PTW is prepared by PA. → Isolating Authority (IA)

2 Close all valves to the CFS, vent, and drain the space. → Performing Authority (PA)

Install positive mechanical isolations (Rated Blinds) to

→ Performing Authority (PA)
3 all pipes attached to the CFS. Install electrical isolation → Isolating Authority (IA)
at the Substation. Enter all details in the LOTO Plan.
Vent and drain the confined space. If it is contaminated
with a hazardous substance, consider cleaning the → Performing Authority (PA)
4 hazard before any other work is performed in the CFS. If → Issuing Authority (Ops Supervisor)
the CFS is hot, ensure sufficient time is taken to cool
down.
Install outside access scaffolding if required. Bring
→ Performing Authority (PA)
5 rescue equipment to the entrance to the confined
space. Install warning signs and barriers.
The first gas test is done at the entrance and, where
6 appropriate, then noted in the gas test log.
→ Unit HSE Engineer

Local exhaust ventilation is in place and working; a

portable draeger-type gas monitor is positioned at the
end of the ducting to check air intake quality.
7 The second gas test is done after sufficient ventilation
→ Unit HSE Engineer

has been done. ERT notified of CFS Entry Time & Date,
Location.
The second area inspection is done, and if all hazards
have been controlled, HSE will complete the safe work → Performing Authority (PA)
checklist. If it is OK, the issuing authority will sign the → Issuing Authority (Ops Supervisor)
8 PTW at the location. A safety briefing is done, and
→ Isolating Authority (IA)
→ Unit HSE Engineer
workers sign onto PTW and the rescue plan. An → Workers
attendant is in place with a recall device.
First, entrants will install low-voltage, intrinsically safe
lighting. Access ladders and or scaffolding can be → CFS Attendant
installed. All workers are to wear suitable rated → Workers trained in CFS
9 PPE/RPE, including a 4/1 Personal gas monitor and → Unit HSE Engineer
(ex) two-way radio. If using SCBA, a complete check of → Performing Authority (PA)
the equipment must be done, including air quality.
Harness and retrieval devices shall be in place.
When work is complete, the CFS will need to be put → Isolating Authority (IA)
10 back into service after the removal of any access → Performing Authority (PA
equipment request that all LOTO devices be de-isolated.
Once de-isolation has occurred, perform a walk-down
and hand it over to the unit ops supervisor. → Performing Authority (PA)
11 → Issuing Authority (Ops Supervisor)

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11 CONFINED SPACE OXYGEN LEVELS

Some areas may not seem like confined spaces but may be designated so because of the
presence of specific hazards, such as:
→ An FM200 fire-fighting system protects cellar rooms in PIBs
→ Fin-fan cages with rotating parts
→ Drain systems that may have H2S in them
→ Analyzer Shelters that can leak gases.

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12 LOW OXYGEN LEVELS DANGERS.

Low oxygen levels are produced through:

o Displacement
o Depletion
o Chemical reactions.
Gases such as methane or nitrogen can displace oxygen, creating oxygen-deficient
atmospheres. They may be used intentionally to prevent the formation of flammable mixtures
inside a storage tank.

Oxygen-deficient atmospheres can also be the result of depletion through work performed (for
example, welding) or chemical reactions (for example, rusting within a tank).

Human beings are highly susceptible to asphyxiation through oxygen deficiency. A person
deprived of sufficient oxygen may not be able to move, be unable to rescue themself, and
display a lack of concern about an imminent loss of consciousness.
An individual entering a confined space with a deficient oxygen level usually shows no warning
symptoms but collapses immediately. Death will result unless the individual is quickly rescued.

O2 21% Typical O2 concentration in air

% air.
15–19% First sign of hypoxia. Decreased ability to work
strenuously. May induce early symptoms in persons
with coronary, pulmonary or circulatory problems.
Respiration increases with exertion, pulse up, impaired
12–14% muscular coordination, perception and judgment.

Respiration further increases in rate and depth, poor

10 –12% judgment, lips blue.

Mental failure, fainting, unconsciousness, ashen face,

8 –10% blue lips, nausea, vomiting, inability to move freely.
6 minutes - 50% probability of death.
8-minutes —100% probability of death.
6 – 8% Coma in 40 seconds, convulsions, respiration
ceases, death
Coma in 40 seconds, convulsions, respiration
4 – 6% ceases, death.

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12.1 OXYGEN ENRICHMENT

There is an increased risk of fire and explosion from high oxygen levels. They can be
expected to be more violent and intense at these levels.

Higher than normal oxygen levels can result from oxygen leakage during oxy/acetylene
welding operations.

12.2 FLAMMABLE ATMOSPHERES

A gas mixture is flammable when the concentration of flammable material in the air is within
the Lower and Upper Explosive Limits (LEL and UEL). A flammable mixture presents a fire
and explosion risk that can kill or injure.

High oxygen levels, which can occur from leaking oxygen cylinders, widen the range of Lower
and Upper Flammability Limits, thereby increasing the possibility of fire.

The ignition of a flammable atmosphere within a confined space is particularly dangerous

because there are limited means of escape, and the depletion of oxygen coupled with smoke
and heat generation can quickly render a person unconscious and unable to escape.

WARNING.
Never store any gas cylinders/tanks in a confined space, regardless of their contents.

Flash back arrestors must be

fitted and rated gas fittings to
all gas cylinders.

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13 TOXIC HAZARDOUS ATMOSPHERES

Toxic and hazardous materials can result in many different adverse health effects,
ranging from mere skin itchiness to death. The severity of a human body's reaction
depends on the material, concentration, duration of exposure, method of entry into
the body, and individual susceptibility. Inhalation is the most common method of
entry into the body within a confined space. Many toxic/hazardous substances exist in
the refinery process units; here are a few to know about.
o Benzene
o Sulfur dioxide
o Petroleum coke
o Polycyclic aromatic hydrocarbons
o Hydrofluoric Acid / Hydrogen Flouride
o Ammonia
o Hydrogen Sulfide
o Refractory dusts
o Catalysts.

People going into the process units and any confined space shall know the hazards; you should
not go in if you do not know. Poisonous or explosive hazardous substances are amongst the
most frequent causes of incidents associated with work in confined spaces and containers. A
correctly and carefully performed clearance measurement before authorizing entry into a
confined space is, therefore, a mandatory safety measure and must be included in all task risk
assessments (TRA) as part of the confined space evaluation carried out by the operations
supervisor issuing authority and the unit HSE Engineer before any confined space entries take
place at the Refinery. This is a lifesaving rule and cannot ever be compromised.

The maximum amount of toxic material a person can safely tolerate can be represented
differently.
❖exposed
The Occupational Exposure Limit (OEL) is the maximum value a worker should be
to, through inhalation, for an eight-hour working day without harmful
effects.
❖valueOnthat
the other hand, the Short-Term Exposure Limit (STEL) expresses the maximum
a person can withstand for 15 minutes without harmful effects.
The choice of which value to utilize depends on the task/activity's purpose.
Exposure to toxic substances can lead to both short-term and long-term adverse health effects.
Both conditions are undesirable, and steps should be taken to avoid exposure to dangerous
amounts of toxic substances.

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Checking the Safety Data Sheets (SDSs) for the safe working concentration levels of hazardous
chemicals handled at the Refinery is essential in carrying out Control Of Substances Hazardous to
Health. (COSHH) health risk assessments (HRA).

14 SAFE CLEARANCE MEASUREMENT.

Safe clearance measurement is one of the most demanding tasks that can be carried out with
mobile gas detectors, and this ranges from task risk assessment to performing the measurement
and evaluating the results. The person responsible for performing a CFS safe clearance
measurement must have in-depth expert knowledge about the properties of the various
hazardous substances, handling of the gas testing equipment instruments, and specific features
of the respective plant and equipment being measured. Gas tests shall be performed before the
activity commences, which means they will be performed immediately before the activity. If you
decide to have lunch after performing the CFS safe clearance gas test measurement, another gas
test clearance will have to be performed, and this is a safety rule on the Refinery. If the CFS has
to be left open without the activity taking place, this can cause changes in the atmosphere.
Environmental factors such as temperature and ventilation can change the atmosphere
immediately. Workplace Exposure Limit (WEL) must be carefully monitored as working hours
tend to be longer during equipment shutdowns, and reduction factors should be considered.
These factors equalize the differences between the WEL temporal reference values and the
actual working hours. A WEL refers to a total exposure time of 8 hours per day. However, usual
working hours are 12 hours during plant shutdowns. In these cases, the alarm threshold of the
gas detectors must, therefore, be lower than the WEL.

14.1 FUNCTION TESTS AND CALIBRATION

Most gas test manufacturers recommend that the battery life and alarm function every time you
use the equipment. Each time the equipment is used, it shall first be bump-tested with test
gases if the maximum allowable time between function testing is 24 hours or a maximum of 3
shifts. To determine the reference point of the gas detector, it is necessary to calibrate the zero
point. The calibration must be done in an environment free of hazardous substances, ideally in
the fresh air.

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14.2 REPRESENTATIVE ATMOSPHERIC MEASURING POINTS.

If methane is to be detected and the gas sample is taken from the bottom of a container, it
should become evident to everyone that the risk of an explosion is still present. Methane is a
light gas that quickly mixes with ambient air. The methane cloud tends to rise to the top. The gas
concentration on the bottom of the container does not indicate how explosive the atmosphere
is. If hydrogen sulfide is to be detected in a container, a gas sample taken from the upper part of
the container is not reliable. With a 34 g/mol molar mass, H2S is significantly heavier than air (29
g/mol) and thus sinks to the bottom. Both examples show that measurements taken from the
wrong location can, in some cases, lead to death.

As a rule of thumb, Light gases quickly mix with air, the volume of a cloud increases rapidly, and
the cloud rises to the top. Therefore, measurements should be performed in the open
atmosphere close to the leak. Increases in concentration take place in the upper parts of
containers.
Heavy gases can flow on the bottom like liquids, pass obstacles, or stick to them; they barely mix
with the ambient air and have a high range. Measurement of these gases should be performed
at the bottom.
The following aspects should also be considered:
→ Type and shape of the equipment/container/vessel or confined space: Almost no tank is
in a 100% level even position. Heavy gases accumulate where the bottom is low, and
light gases accumulate at the highest position. Dead legs should also be noted.
→ Temperature. Suppose gases are heated, for example, because the sun has been shining
on a tank for many hours in mid-summer. In that case, the molecules begin to move
faster, whereby the speed of the diffusion (mixture with ambient air) increases.
→ Ventilation: Air currents change the position and concentration of gas clouds. Also
important: The container where work activities are carried out cannot always be
separated from the pipelines. In this case, it must be determined whether gas can flow
in, and additional suitable protective measures must be taken, for example, with regard
to the personal protective equipment that the entrants will need.

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15 GAS DETECTING

When detecting gas, you first need to know:

o What gases could be present in the equipment/ container/CFS?
o Is the hazardous substance to be detected heavier or lighter than air? Information can
be found on the safety data sheets (SDS)

15.1 HOW TO DETERMINE WHETHER A GAS IS HEAVIER OR LIGHTER THAN AIR?

For example, the molar mass of the compound can be compared with that of air (29 g/mol). The
molar mass of the compound is calculated by the sum of the molar masses of the elements and
by multiplying them by their index numbers. The relative atomic mass of each element can be
found in the periodic table under the written name of the element.
Hydrogen Sulfide.
M(H²S) = 2 X M(H) + M(S)
M(H²S) = 2 X 1,01 g/mol + 32,07 g/mol = 34,09
Result: M(H²S) > M (air) Hydrogen sulfide is heavier than air.

Methane
M(CH⁴) = M(C)) + M(H)
M(CH⁴) = 12,01 g/mol + 4 X 1,01 g/mol = 16,05
Result: M(CH⁴) < M(air). Methane is lighter than air.

A lack of oxygen in the atmosphere only becomes a hazard to people when the content falls
below 19%. Why, for example, is a content of 20.5% already an alarming value in clearance
measurement? In an atmosphere with a slightly reduced oxygen content, the threshold values
for explosive and hazardous substances may have already been exceeded. Air consists of four-
fifths nitrogen and one-fifth oxygen.
If an inert gas is released in this mixture, not only will the oxygen content be reduced by the
displacement, but also the nitrogen content will be reduced by four times. If, for example, 10 vol
% helium is released, oxygen concentration will be reduced by 2 vol. %, and Nitrogen
concentration will be reduced by 8 vol. %.

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16 GAS DETECTING

What does this mean by looking at it in reverse order. Suppose a gas detector measures oxygen
content pg 20.5 vol. % in a container. The released gas has not only 0.4 vol. % oxygen but also
1.6 vol. % nitrogen; thus, a total of 2.0 vol. % of the unwanted substance is in the atmosphere.
This is roughly equivalent to 20,000 ppm, a deadly concentration concerning almost all
hazardous substances.
As a rule of thumb, 5 vol. % carrier gas reduces the oxygen content by 1 vol. % in a confined
space. 1 vol. % of a concentration is equivalent to 10,000 ppm! The workload of the task must be
assessed. See below.

IMPORTANT.
The oxygen value alone is not reliable, and an oxygen content of 20.9 %
does not mean that the air is free of hazardous substances !

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17 GAS TESTING

An SQEP competent authorized Gas Tester must conduct atmospheric testing to:

Evaluate the hazards of the confined space and

Verify that the confined space is safe for entry by taking gas tests from suitable access points,
Complete the gas test log and the CFS safe work checklist (SWC in appendices)
IMPORTANT ⁂ Care must never be taken to NEVER trust your senses to determine whether the
air quality in a confined space is safe! You CANNOT see or smell toxic or combustible gases and
vapors, nor can you determine the level of oxygen present.
Order of Testing
1. FIRST STEP. Test oxygen in the atmosphere

2. SECOND STEP. Test flammables in the atmosphere

3. THIRD STEP. Test toxics in the atmosphere.

An oxygen test is performed first because most combustible gas meters rely on the
presence of oxygen to function and will not provide reliable readings in an oxygen-deficient
atmosphere. Combustible gases are tested for next because the threat of fire or
explosion is both more immediate and more life-threatening, in most cases than exposure
to toxic gases and vapors.

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18 VENTILATION

Dangerous levels of substances are easily formed within confined spaces due to poor natural
ventilation. Some toxic atmospheres result in death almost immediately, while others can
impede the ability of a person to escape the area, eventually leading to death.

Although hydrocarbons are mostly regarded as fire and explosion risks, many have narcotic
effects on humans. Initial signs are typical of intoxication. Failure to respond to verbal
commands occurs roughly at the Lower Explosive Limit (LEL), corresponding to about 50% of
the general anesthetic dose required for surgical operations. These narcotic effects can occur
very quickly—within only four breaths! Ventilation shall be used to ventilate hazardous gas
and air-particulate substances and push in clean, fresh air.

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Important. Check wind direction

force in clean-air ventilation cannot
VENTILATION be contaminated. Portable gas
monitor to be at the air intake.

Depending on whether the gas is lighter

or heavier than air will decide where the
exhaust ventilation is situated, if heavier
than air it will be a the base if lighter than
air at the top of the container, the force
ventilation goes opposite the exhaust
ventilation ducting.

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19 EQUIPMENT

Depending on the type of confined space (CFS) entry being planned and the task risk assessment
controls, equipment must be ready to be deployed; all equipment, regardless of what it is, must
be inspected as fit for use before being used. Equipment is also determined by hazards
associated with the confined space. The ERT shall be notified of all CFS entries. The rescue plan is
mandatory for all CFS entries and shall list all equipment that is required on the rescue plan,
such as:

Rescue Equipment.
→ Rescue ropes and carabiners, ascenders
→ Winch and or tripod
→ Rescue stretcher/sked type that a crane can use
→ Self-Contained Breathing Apparatus (SCBA)
→ Two-way Intrinsically safe (IS) radios
→ 4/1 Personal Gas Monitor / portable area gas monitors
→ Intrinsically safe torch/flashlight
→ Steel rope ladders
→ Portable fire extinguishers
→ Emergency first aid equipment and defibrillator.
→ Emergency Breathing Air Cylinders and lines/masks
→ Chemical suites + PPE/RPE.

Environmental Inhalation & Absorption / Temperature Hazards.

Specialized equipment will be required for CFS entries in places that have contained hazardous
substances, such as:
→ SCBA, full face mask, and cylinder or airline fed from the clean air bottle bank
→ Chemical suits, boots, gloves.
→ Local Exhaust Ventilation (LEV) with Ground Force Circuit Interrupter (GFCI) has multiple
units to force clean air in and extract hazardous contaminated air/dust out to a safe
location, such as a closed drain.
→ Decontamination station for taking off contaminated PPE.
→ A suitable multi-gas testing instrument and 4/1 personal gas monitors are to be used.
→ Rest shelters will be provided with clean drinking water to cool down when higher
ambient air temperatures are present.

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Fall Exposure Hazards.

The following equipment shall be considered in the task risk assessment (TRA) to prevent falls
either outside or inside the confined space, such as:
→ Self Retractable Lanyard (SRL).
→ Personal harness with two lanyards.
→ Scaffolding safe access platforms.
→ Lifelines, nets.

Electrocution and Pressure Hazards.

The following equipment shall be considered in the TRA to prevent electrocution and pressure
hazards, such as:

→ Mechanically rated blinds/spades/lockout equipment installed and monitored by the

Isolation Authority. Air gaps in pipes are allowable, provided the flange is chained to
prevent installation.
→ Open vents and drains, locked open.
→ Assured grounding of all equipment with OHMS resistance test done
→ All electrical equipment shall be turned off and locked out by Isolating Authority.

RESCUE EQUIPMENT TO BE LISTED IN RESCUE PLAN & INSPECTED BEFORE USE.

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20 RESPIRATORY PROTECTIVE EQUIPMENT (RPE)

Respiratory protection of workers entering confined spaces should be determined based on

the following principles and specific task risk assessment guidelines.
Entry dispensation limits.
CRITERIA Oxygen Flammable Toxic

Entry without breathing

apparatus but with LEV 20.8% <1% LEL <5% OEL

Specific Task risk assessment 19.5-23.5% up to 20% LEL* up to STEL

Unsafe—too high for normal

breathing air-purifying respirators <19.5% or >23.5% >20% LEL >STEL

20.1 PROTECTION FACTORS

The protection level expected by a specific class of respirators or the level of protection that a
specific wearer may achieve. In other words, there is A difference between wearing a specific
respirator type and wearing no respirator at all. Protection factors are a vital tool to assist in
choosing the appropriate level of respiratory protection.

The decision on choosing appropriate respiratory protection should be based on the overall
analysis of the specific conditions and not on protection factors alone. Such as:

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20.1 PROTECTION FACTORS

General Requirements to use APR.

❖ O2 Minimum of 19.5% - The type and concentration of contaminate must be known,
❖ Not allowed in poorly ventilated areas or confined spaces with contaminants, such as
tanks, vessels, tunnels, pits, etc.
❖ Contaminant must have apparent warning properties, smell, or taste
❖ Concentration level below imminent danger life health (IDLH).

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21 LEAKAGE FACTORS OF RESPIRATORS.

Respirators may leak and cause health issues, such as:

❖ Filter does not remove 100% of particles (filters remove 80% to 99.97% of particles
depending on the class of respirator)
❖ The mask does not correctly fit the user due to the size
❖ Leakage along sealing lines due to face shape, facial hair, or long hair in sealing line
❖ Inconsistent quality of respiratory protective device (RPD) maintenance
❖ Inconsistent donning and use
❖ Mask leakage of parts, lenses, valves, gaskets, and seals.

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22 PROTECTIVE SUITS.

Dangerous substances may escape during abnormal operations or upsets, particularly during
shutdowns or maintenance, making wearing a chemical protection suit necessary. Workers often
have to remove residues of various materials and protect their skin from direct contact while
cleaning. It is essential to wear the right suit for the job as different suits have different
mechanical and chemical resistance protection from penetration of hazardous materials. The
rule of thumb is that the longer a chemical needs to penetrate a material, the more effective the
protection of the materials needs to be. So resistace criteria are important in EN 943 and EN
14605.

SUIT TYPE PROPERTY

Type 1. Gas-tight
Type 1a. Gas-tight
Type 1b Gas-tight
Type 1c Gas-tight
Type 3. Protects against fluids
Type 4. Protects against spray
Type 5. Particle protection
Type 6. Limited protection against spray.

To find out how long a material can resist SUIT CLASS BREAKTHROUGH
TIME
penetration from a certain chemical, test
1 >10 Minutes
procedures have been defined in DIN-EN-ISO-
6529. The breakthrough time is clocked, indicating
2 >30 Minutes
how long it takes to penetrate from outside to
inside. The breakthrough time is a core factor in
3 >60 Minutes
determining the protection offered by a chemical
suit.
The chemical protection suits include six different 4 >120 Minutes
classes based on the protection offered. Safety
Data Sheets (SDS) information on chemicals must 5 >240 Minutes
be studied to determined the suitable safe
protection required when selecting chemical suits. 6 >480 Minutes

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23 FIVE STEPS TO FIND THE RIGHT SUIT PROTECTION

Step 1. What work needs to be performed?

In the Refinery, numerous tasks require workers to wear chemical protection suits. Typical
examples include pre-entry safety measures, the transfer of chemical substances, and filling,
transferring, or emptying containers—service and maintenance, tank and strainer cleaning, and
responding to emergencies. The activity type and duration of the application determine the
necessary protection required.
Step 2. Determine what the risks are with the hazardous materials.
Hazardous materials may take many forms, which determines the risk exposure. Whether a
material is in a gaseous or liquid state is decisive as to whether splash protection is sufficient or
gas protection is needed. If the hazardous material is very cold, such as a liquefied gas, the suit
material must not become brittle or break when exposed to the cold. The protective suit must
be flame-resistant if the hazardous material is flammable at room temperature. If there is a
danger of explosion from the hazardous material, the suite must have the appropriate electro-
static properties.
Step 3. Where will the work be performed?
For work activities in unfamiliar environments, it is often necessary to maneuver between sharp
surfaces. The protective suit must have robust mechanical properties to prevent tears and
punctures. If SCBA is being used, ensure the suit fits comfortably so that the SCBA can be
attached without restricting movement.
Step 4. Is a breathing Apparatus needed?
Should no breathing apparatus be required, normal FRC overalls should be sufficient to protect
the worker from any cuts or abrasions. If you have to use a filtering-type respirator, wearing a
suit with a full face mask is best. If SCBA is used, ensure the suit fits comfortably so that the
SCBA can be attached without restricting movement.
Step 5. How can hazardous materials contamination be removed?
Should the task entail getting hazardous chemicals on the suit, a breathing apparatus should be
worn on the inside. A disposable suit should be considered if it is so contaminated that it cannot
be cleaned. Decontamination stations should be set up near the confined space to
decontaminate contaminated suits and PPE.

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24 UNDERSTANDING CHEMICAL PROTECTION

Before selecting a suitable protective suit or any other PPE, check the manufacturer's data sheet
on the protection given to ensure it will be adequate for the activity.

24.1 WHAT ACCESSORIES DO I NEED FOR CHEMICAL PROTECTION?

Boots and Gloves

Should they not be integrated into the chemical suit, keep the following in mind when
making a selection:

❖ Suitability of the chemical class of the boots

❖ Ease of putting them on and taking them off

❖ Cotton and leather gloves are not permitted for chemical protection.

Cooling. Working in a chemical suit can be demanding and strenuous. It must be listed in the
TRA as a hazard if the temperature increases, increasing the risk of cardiovascular failure. Some
suits have ventilation systems to keep the temperature down. Alternatively, an external clean
breathing air supply can be attached to the suit. Another way to reduce the temperature is to
use cooling vests under the suit to keep the worker cool. Work and rest times will need to be
established in the task risk assessment (TRA).

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25 RACI CHART FOR CONFINED SPACE ENTRIES.

HSE MANAGER

HSE ENGINEER

/maintenance

Management
ATTENDANT
OPS Issuing

Performing

Operation
WORKERS
Authority

Authority

Authority
TASK

Isolating

Refinery
Manger
ERT
CFS
CFS Training C I A R I I I I I I
Preparation of RAMS C R I I I I I I A I
Review of RAMS C I R C I I C I A I
LOTO Installation C C I I I I I R A I
Gas Testing C C I R I I I I A I
Rescue Plan
C C A R I I C I I I
development
Emergency Response C C A I I I R I I I
Issuing CFS Permit R C I C I I I I A I
Performing the
C A I I C R I I I I
activity in the CFS
STOP work activity if
R R R R R R R R R A
it is unsafe

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26 MANDATORY REQUIREMENTS FOR EACH JOB ROLE.

WHO WHAT
Workers: → Attend CFS training
→ Follow CFS Procedure
→ Follow PTW & TRA, Rescue Plan
→ Wears suitable PPE/RPE
→ Must be medically fit to enter a confined space with up-to-date
medical fitness to work certificate.
→ STOP if unsafe, or the attendant instructs them to STOP and exit.
→ Exit if the gas alarm is activated
Attendant: → Shall always be in place, if they have to take rest/toilet break a
suitable competent person must be in place till they take their break
→ Never enters a confined space, even in an emergency
→ Follow the CFS procedure
→ Has a recall device and 2-way-radio to call ERT in an emergency
→ Keep an up to date and time log sheet for entrants and when they
exit. Must be able to communicate with ERT and crew
→ Must be trained in CFS and first aid.
Issuing Authority → Attends training is SQEP competent for their role
Unit Operations → Reviews RAMs safe systems of work
Supervisor: → Visits the work location and carries out a workplace inspection
before signing the PTW at the work location.
→ Monitors all work activities in their unit/area of responsibility.
→ Prevents other permits from being issued when a SIMOP is a risk for
confined space activity.
Isolating Authority → Follows the Stored Energy Procedure
→ Is SQEP Competent for energy isolation,
→ The electrical appointed person shall have switching certifications,
and the mechanical appointed person must also be certified.
→ Put in suitable positive isolations before any CFS entries take place
→ Visits the site and demonstrates to the work crew that the systems
are vented, drained, depressurized, and de-energized, gives
completed LOTO Plan to Performing Authority to be included in
RAMS. Gives marked up P&ID to the PA
→ Always first lock on and last lock off before handing back to the
unit/area the operations supervisor at PTW close out.
→ Must be trained in emergency first aid.
Performing → Must be SQEP Competent for their role
Authority → Attended PTW training, CFS Training, Stored Energy Training, First aid
→ Develops the RAMS, organises the LOTO
→ Ensure that the CFS has hazardous substances removed before entry
→ Gives task risk assessment briefing before signing the PTW
→ Present in the area and contactable by 2-way (IS) radio whenever a
CFS entry is underway. Conducted the attached CFS Checklist

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MANDATORY REQUIREMENTS FOR EACH JOB ROLE.

WHO WHAT
Unit/Area HSE → Attend CFS training, first aid training, PTW training
Engineer: → Follow CFS Procedure
→ Reviews the RAMS and PTW
→ Develops the Rescue Plan
→ Wears suitable PPE/RPE
→ STOPs work activity if unsafe
→ Informs ERT of any CFS entries
→ In an emergency, activates the alarm, guides people to muster point
→ Carries out CFS Inspection using the Safe Work Checklist before any
entry occurs or the PTW is signed onto at the work location.
ERT → Shall always be in place, if they have to take rest/toilet break a
suitable competent person must be in place till they take their break
→ Are SQEP Competent
→ Follow the CFS procedure
→ Must be trained in CFS and emergency first aid.
→ Must be medically fit for duty for CFS entries.
→ Carries out at least one CFS rescue practice drill each month
→ Review rescue plans and shall be on standby to rescue with suitable
equipment when required.
Operations / → Attends training and is SQEP competent for their role
Maintenance → Review their teams for training needs analysis
Managers → Visits the work location and carries out workplace inspections
→ Monitors all work activities in their unit/area of responsibility.
→ Act as a team safety leader, encouraging people always to follow the
HSE Plans & Procedures.
OHS Professionals → Follows the Medical Plan
→ Is SQEP Competent for occupational health
→ Gives first aid training
→ Carries out health risk assessments for all job roles
→ Carries out respirator face-fit tests
→ Advises on OHS for all chemicals and hazardous substances
Refinery Manager → Approves the Confined Space Procedure
→ Ensures suitable and sufficient Resources are in place to conduct all
confined space entries safely.
→ Safety First Champion for the Refinery.
HSE Manager → Ensures that the HSE Plan and Procedures are kept up to date
→ Provided confined space training when required
→ Provided ERT with practical CFS training drills & exercises
→ Ensures SQEP competent HSE Engineers are in place for each unit or
area for each shift on the Refinery
→ Investigate any incidents and writes incident reports
→ Advises Refinery Management Team (RMT) on all HSE matters.

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27 TRAINING

Confined space entries are high-risk activities controlled by reducing the risk to As Low As
Reasonably Practicable using a Task Risk Assessment (TRA). Everyone who has a role in confined
spaces, whether a worker or support person, shall be a Suitably Qualified Experienced Person
(SQEP). Everyone associated with the confined space entry shall be competent and attend the
Refinery HSE Training. It is mandatory to attend training every 12 months and have the
following:

✓ Attended the Karbala Refinery HSE Induction

✓ Attended and passed the Permit-To-Work Course

✓ Attended and passed the Stored Energy Course

✓ Have an up-to-date (within 12 months) medical fitness-to-work certificate from a

medical professional.
✓ Must be SQEP competent in their job role

✓ HSE Engineers must have gas test training certification

✓ Attended a First Aid and CPR course.

✓ Attended a 4/1 Personal Gas monitor course

✓ Been face-fit tested for respiratory protective equipment

✓ Electrical authorities must have a certified electrical safety switching course certificate

✓ Use all tools and equipment safely, such as non-sparking tools (IS) Radios.

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28 HSE ENGINEERS CFS INSPECTION.

The unit HSE Engineer shall inspect the confined space area before the operations issuing
authority can sign the CFS permit. The performing authority permit receiver supervisor will
participate in the inspection. The following shall be checked before entry takes place:

# HSE CONFINED SPACE INSPECTION

The CFS has been evaluated for energy isolation requirements, and all energy sources
1
are locked out and tagged as per the LOTO Plan.

2 The hazards have been identified and controlled, and it is safe to start.

3 Gas testing frequency has been established.

4 Ventilation is in place and working.

An attendant is in place, and the method of communication is agreed to and tested

5
before entry.

6 The breathing apparatus is in good working condition if required.

7 The rescue plan is in place and ready to be used.

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29 APPENDICES

Performing Authority Supervisors Checklist to be completed for each confined space entry.

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HSE ENGINEERS CHECKLIST.

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GLOBALLY HARMONISED STANDARD HAZARD PICTOGRAMS .

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REVISON: 1 17 MARCH 2024 39