FAS TUBE MILLS & ENGINEERING INDUSTRIES

COMPANY SAFETY PROCEDURE

Procedure for Confined Space Entry

Procedure
Procedure for
for Confined
Confined Space
Space Entry
Entry

DOCUMENT APPROVAL BLOCK

NAME & DESIGNATION SIGNATURE

Prepared (Mr. Muhammad Ramzan Noor)

by:
(General Manager)

Reviewed & Zohaib Farrukh Butt (Director)

Approved
by: Ahsan Mahmood Butt (Chief Executive)

Revision 01
No.:
Date of 01-01-2016
Issue:

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Table of Contents

1. Introduction................................................................................................................................... 3
1.1. Background............................................................................................................................ 3
1.2. Purpose.................................................................................................................................... 3
1.3. Distribution / Target Audience........................................................................................ 3
1.4. Changes To The Document................................................................................................ 3
1.5. Step-Out Approval................................................................................................................ 4
1.6. Alarp......................................................................................................................................... 4
2. Roles And Responsibilities......................................................................................................... 4
3. Confined Space Entry Procedure............................................................................................. 6
3.1. Preparation For Confined Space Entry..........................................................................6
3.1.1. Potential Hazards Associated With Confined Space Entry ...........................6
3.1.2. Planning And Risk Assessment............................................................................... 6
3.1.3. Gas Freeing And Flushing......................................................................................... 8
3.1.4. Working Atmosphere................................................................................................. 8
3.1.5. Ventilation................................................................................................................... 10
3.1.6. Positive Isolation....................................................................................................... 10
3.1.7. Use Naked Flames And Arc..................................................................................... 10
3.1.8. General......................................................................................................................... 10
4. Confined Space Entry Process................................................................................................ 11
5. Appendix 1 – Abbreviations.................................................................................................... 14
6. Appendix 2 – User Feedback Page........................................................................................ 15

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1. INTRODUCTION

1.1. BACKGROUND
The nature of industry in which FAS operates frequently requires personnel to enter
‘Confined Spaces’ to carry out inspections and / or maintenance and repair work. A
confined space:
 Has limited or restricted means of entry or exit
 Is large enough for an employee to enter and perform assigned work, and
 Is not designed for continuous occupancy by the employee.

A “permit-required” confined space is one that meets the definition of a confined space
and has one or more of these characteristics:
 Contains or has the potential to contain a hazardous atmosphere,
 Contains a material that has the potential for engulfing the entrant,
 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, and/or contains any other recognised
serious safety or health hazards. These shall include but are not limited to:
 Process vessels i.e. separators, pressure vessels
 Storage tanks
 Compressor enclosures
 Heaters and boilers
 Flare and vents systems
 Cellars and pits
 Culverts

1.2. PURPOSE
The purpose of this procedure is to provide all personnel, FAS or contract, with
clear and concise instructions for entering or working within a confined space.

1.3. DISTRIBUTION / TARGET AUDIENCE

This procedure is intended for use production and maintenance personnel and any
other parties tasked with carrying out work covered by this procedure on behalf of
FAS.

1.4. CHANGES TO THE DOCUMENT

Responsibility for the upkeep of the Document shall be with the Functional
Production Manager, the Owner. Changes to this document shall only be
authorised and approved by the Owner.
Users of the Document who identify inaccuracy or ambiguity can notify the
Custodian or his/her delegate and request changes be initiated. The Requests

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shall be forwarded to the Custodian using the “User Feedback Page” provided in
this Document.
The Document Owner and the Document Custodian shall ensure review and re-
verification of this procedure every 3 years.

1.5. STEP-OUT APPROVAL

This procedure is mandatory and shall be complied with at all times. Should
compliance with the procedure be considered inappropriate or the intended activity
cannot be effectively completed or safely performed, then step out approval must
be obtained from the Asset prior to any changes or activities associated with the
procedure being carried out.

1.6. ALARP
ALARP is the acronym for ‘As Low as Reasonably Practicable’ which simplified
means, ‘reducing the risk to a level at which the cost and effort (time and trouble) of
further risk reduction are grossly disproportionate to the risk reduction achieved’.
Full Compliance to FAS Standards and Procedures is a key element in achieving
ALARP

2. ROLES AND RESPONSIBILITIES

Asset Holder  Accountable for ensuring all HSE Procedures are

implemented within the asset
Production Coordinator  Responsible for ensuring that HSE Procedures and
Risk Assessments are conducted and are adhered to
in the area
Responsible Supervisor  Inspect work site with Permit Applicant
 Check Job Safety Plan and ensure Risk Assessments
are completed for each Confined Space Entry.
 Authorize the Permit to Work (PTW)
 Check Section 2 of the ‘Confined Space Entry
Certificate’
 Authorize the isolation on Mechanical Isolation
Certificate
 Authorize ‘Entry’ to confined space

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Area Authority  Validates PTW

 Check Job Safety Plan and ensure Risk Assessment
controls are adhered to.
 Conduct isolations
 Inspection of work site on completion when PTW is
closed
 Check Section 2 of the ‘Confined Space Entry
Certificate’1
 Authorize ‘Entry’ to confined space2
Permit Applicant  Applicant for PTW
 Conduct safety checks of site and Risk Assessment
with Responsible Supervisor prior to any works being
carried out
Permit Holder  Carry out ‘toolbox’ talks prior to works being carried out
 Oversee safety of personnel and work within ‘confined
space’
 Ensuring strict adherence to all Safety Procedures, Job
Safety Plan, Risk Assessments and Work Instructions
 Checking condition of work site on completion of all
works

Standby Personnel3  Maintain register of entry / exit of personnel during work

in confined space
 Maintain communication and visual contact with all
personnel in the confined space
 Maintain emergency rescue equipment at all times
during work in the confined space
 Record any incidents during work process

1
If delegated by Responsible Supervisor
2
If delegated by Responsible Supervisor
3
Nominated on the Confined Space Entry Certificates

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3. CONFINED SPACE ENTRY PROCEDURE

3.1. PREPARATION FOR CONFINED SPACE ENTRY

CAUTION: Entry into confined spaces exposes personnel to risk in addition
to those associated with the work / task. Entry into a ‘Confined Space’ should
only be considered if the work cannot be accomplished from an external
location.

3.1.1. POTENTIAL HAZARDS ASSOCIATED WITH CONFINED SPACE ENTRY

Potential hazards associated with confined space entry are recognised. These
hazards can be any or all of the following:
 Oxygen deficiency or enrichment
 Flammability (fire and / or explosion)
 Residual liquids, or solids and associated toxic or other noxious gases
 Chemical hazards
 Physical hazards
 Number of personnel working within the confined space
 Restricted entry / exit
 Narcotic and anaesthetic effect of hydrocarbon gas and vapours

3.1.2. PLANNING AND RISK ASSESSMENT

The first priority is to consider if the work in the confined space can be limited or
avoided. Alternatives may be:
 Residues may be removed from the outside using water jetting or in place
cleaning systems.
 In some cases it may be possible to see inside without entering by using a
boroscope.
 Use of non invasive inspection techniques
If the work is to be carried out in a confined space a risk assessment shall be
completed covering all activities that will be carried out both inside and outside of the
space.
Personnel selected for confined space entry shall have the correct level of
competence, experience and knowledge as indicated by the risk assessment. It will
be necessary to include Vendors / 3rd parties or HSE professionals in this task.
The risk assessment will consider but is not limited to:
 Previous contents of the confined space
 Internal temperature and humidity of confined space
 Ingress of substances
 Oxygen deficiency or oxygen enrichment
 Residues

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 Contamination
 Physical dimensions including internal structures or obstacles
 Nature of any work itself, including concurrent activities.
 The maximum number of personnel required to work in the confined space
The outcome of the risk assessment process shall be a Job Safety Plan approved by
the Responsible Supervisor, who shall determines what mitigation must be put in place
based on the Risk Analysis.
Where the risk assessment indicates that properly trained individuals can work for
periods without supervision, it should be ensured that they are competent to follow the
established safe system of work and have been provided with adequate information
and instruction about the work to be done.
The Permit Applicant shall prepare a rescue plan as part of the Risk Assessment
Process suitable for the agreed maximum number of personnel and covering each
entry. This document should be reviewed and approved by the Responsible Supervisor.
Some examples of possible inclusions to the rescue plan are:
 Number of personnel required to provide effective rescue.
 The equipment required for immediate use
 Contingency plans for loss of communication
 Safest route of access and egress with respect to casualty handling
 Removal of unnecessary obstacles, which will hinder rescue operations
NOTE: These issues may limit number of people in confined space
The Permit Applicant must appoint a trained rescue team before work begins. For
efficient functioning, a rescue team must consist of at least two persons. The Permit
Applicant must be sure that the designated rescue team can be deployed quickly in an
emergency and that they will be able to function effectively. If assistance is required this
shall be provided by the Area Fire Service.
The rescue team must be equipped with suitable personal protective equipment to
enable them to function efficiently.
Rescue plans covering the maximum permitted number of personnel will be agreed
and practiced before any entry takes place. If it is not possible or practicable to perform
training exercises before entry, it is the Permit Applicant responsibility to ensure all
parties with responsibilities under this plan are competent in their roles.
Entry into a confined space shall be controlled by a PTW.
All persons holding safety competent roles e.g. gas tester, must be have valid FAS
Passes showing their qualifications.
Personnel required to work safely in confined spaces must have had adequate training
and experience in the particular work involved. Training standards must be appropriate
to the task, and to the individual's roles and responsibilities, so that work can be carried
out.
In order to achieve the above the following conditions require being satisfied and / or
detailed in the Job Safety Plan prior to entry into a confined space:
 All entries into a confined space shall be controlled by the PTW system

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 When entry is required, the confined space shall be physically isolated from all
sources of hazardous substances, and from all sources of energy or motive
power
 Hazardous substances contained within the confined space shall be displaced,
and the space suitably cooled and ventilated;
 The confined space shall be tested for the presence of hazardous substances
and for acceptable oxygen content. If conditions for safe entry cannot be
achieved or guaranteed, additional precautions to be applied, e.g. the use of
breathing apparatus.
CAUTION: Additional to the use of Portable Multi-Gas Testers confined
spaces that have contained hydrocarbons shall be tested using a Photo-
Ionization Detector (PID – e.g. Draeger tube) to confirm that Occupational
Exposure Levels are complied with before an entry is made. This is
particularly important for the very low exposure limits of the carcinogenic
compounds such as Butane, Pentane and Benzene.
 Provision of personal protective clothing and equipment (personal gas
detectors if required), access and egress, standby personnel, and rescue plans
 When a person is in a confined space a standby person shall be in attendance
at all times and the responsible supervisor shall ensure that this person is
authorised and fully briefed on the activity to be undertaken
 Additional hazards, including concurrent activities in the vicinity of, or within,
the confined space are considered
 When entry to a confined space is required using breathing apparatus, only
those persons trained and deemed competent in the use of the breathing
apparatus shall be allowed to enter the confined space
 All personnel involved in the confined space entry shall made aware of the
hazards

3.1.3. GAS FREEING AND FLUSHING

Tanks, towers and vessels that have contained hydrocarbon or toxic materials shall
require gas freeing and ventilation before entry4 can be made.
Gas freeing shall be in accordance with FAS Procedures; once gas freed and
drained5 the confined space can be opened and ventilated. This method may be
employed where high concentrations of toxic gases are encountered.
Flushing with water (produced if available) shall be used on pipe work, tanks,
towers and vessels to remove heavy hydrocarbon deposits before opening for
cleaning and / or maintenance and repair.

4
This may not be the case if the tank or vessel is to be washed and cleaned prior to gas freeing
and ventilation. In such cases personnel entering the space shall be equipped with breathing
equipment.
5
When using water to gas freeing tanks, towers and vessels ensure that high level vents or
man ways / access hatches are open to prevent drawing and negative pressure and risking
collapse.

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3.1.4. WORKING ATMOSPHERE

Gas testing of confined spaces shall only be carried out by an Authorised Gas
Tester and shall be as specified on the PTW and recorded on the Confined Space
Entry Certificate and the Additional Gas Test Record form (if required).
OXYGEN
Confined spaces may only be entered when the atmosphere inside has been
certified as having a safe oxygen (between 20%-21%) content as indicated by
approved detection apparatus.
WARNING: If the oxygen content is less than 20% the vessel MUST not be entered.

FLAMMABLE
Entry into confined spaces where there is any possibility of flammable vapours, gas
testing with an approved PDO explosive meter shall be carried out and recorded.
This meter must be capable of measuring hydrocarbons in an inert
atmosphere if the confined space has been subjected to gas freeing using
nitrogen. The frequency of subsequent testing shall be stipulated on the PTW. If a
reading greater than 0% is indicated the Responsible Person or his delegate must
be notified and any required restrictions or precautions to be taken shall be entered
on the "Confined Space Entry Certificates".
Flammable process hydrocarbon vapours are also hazardous due to their potential
narcotic / anaesthetic effects, and can result in irrational behaviour, loss of
consciousness, or even death. Hazardous concentrations can be related to
flammability limits (Refer to Appendix 1). Continuous ventilation shall be
established within these spaces where possible.

TOXIC
Where toxic vapours may be present and continuous ventilation is not considered
possible or feasible, each man entering the confined space shall wear positive
pressure respiratory6 protection.
If NORM or Mercury is suspected then the necessary external and internal tests
MUST be carried out by competent persons and the results checked and confirmed
by the Production Chemists. If the tests are outside the specified limits, the
confined space should be ventilated continuously and re-tested at regular intervals
until acceptable.
INTERNAL TEMPERATURE & HUMIDITY
For entry to spaces like Waste Heat Recovery Units of gas turbines, additional
hazards may exist. These hazards exist due to the operational service where the
space has been subjected to high temperature. Hazards such as internal
temperature, humidity and hot surfaces should be included in the risk assessment,
and suitable controls put in place. These controls could for example, result in work
duration being reduced accordingly.

6
Respiratory protection for each man in the confined space and for the Standby Personnel
must be provided where the Responsible Supervisor / Permit Holder consider it necessary. At
least one properly connected air mask shall be available outside of the confined space for
rescue purposes.

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BREATHING APPARATUS
For entry in to a confined space without the use of breathing apparatus, tests may
include but are not limited to:
 Oxygen (between 20%-21%)
 H2S shall be no greater than 1ppm
 Benzene shall be less than 1ppm, but preferably zero
 Hydrocarbons in air less than 2% LEL but preferably zero (see Table)
<2% Entry allowed without BA
≥2% and <10 or atmosphere Entry only with BA
unsustainable
≥ 10% No entry allowed

CAUTION: If it is considered that the breathable atmosphere cannot be guaranteed then

entry shall be completed wearing breathing apparatus.

3.1.5. VENTILATION
Ventilation shall be employed to make the atmosphere inside of the confined space
able to ‘support life’. Where the atmosphere in the confined space is flammable or
toxic, forced ventilation will be employed to extract and clean air be allowed to
replace that extracted by natural circulation from a low point.
WARNING: Outside air shall not be forced in to expel the flammable atmosphere as this
may cause an explosive mixture being formed.

3.1.6. POSITIVE ISOLATION

Before any entry is permitted to a confined space positive isolation shall be carried
out as required.
MECHANICAL
Mechanical isolations shall be carried out using ‘spades and blind’ where
applicable, or removal of spool pieces where applicable.
ELECTRICAL
Electrical shall be isolated at the MCC or switchboard. All isolations should be
carried out by a ‘competent person’ and be tagged in accordance with Electrical
Safety Rules and the issue of an Electrical Isolation Certificate which shall be
attached to the PTW.

3.1.7. USE NAKED FLAMES AND ARC

Strict control shall be exercised on the use of ‘naked flames or arc welding’
equipment inside or in the vicinity of confined spaces where flammable vapours are
or could be present. Such works shall require a ‘Hot Work Permit’ to be in force.
Fixed and portable fire equipment, correct for the type of work being undertaken,
shall be provided at and adjacent to the work place.
WARNING: CO2 or dry powder type extinguishers shall not be used inside of confined
spaces when personnel are inside. Accordingly water shall not be used if ‘live’ electrical

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equipment is being used inside the confined space. In the event of a fire personnel shall
be evacuated as quickly and safely as possible.

3.1.8. GENERAL
PERSONAL PROTECTION EQUIPMENT (PPE)
Correct PPE shall be worn at all times while the work is being undertaken.
Specialised PPE required for specific tasks shall be made available to all personnel
involved. The requirements of specialized PPE shall be made on the Job Safety
Plan.
SAFETY HARNESSES / LIFELINES
Safety harnesses shall be provided for all persons working inside the confined
space if the work involves scaffolding or ‘raised’ platforms. Suitable ‘strong points’
shall be made available if not already provided.
Lifelines shall be used at all times by personnel inside the confined space.
PORTABLE POWER TOOLS
Where practical power tools used within confined spaces shall be ‘pneumatic’. Use
of electrically powered equipment shall be kept to a minimum level.The preference
shall also be made to adopt pneumatic lighting for confined spaces rather than
those powered from electrical circuits.

4. CONFINED SPACE ENTRY PROCESS

The following process shall be followed or adapted when undertaking work which
requires ‘entry into a confined space’.
The following Permits and Certificates are associated with Confined Space Entry:
 Permit to Work (PTW)
 Confined Space Entry
 Mechanical Isolation
 Additional Gas Test Record
 Electrical Isolation
The Permits and Certificates shall be completed, signed and attached to the PTW with
a Job Safety Plan (including Risk Assessment) and all relevant drawings and
documents.
1. When confined entry is required to undertake maintenance, repair or
modification it must be accessed if a full or partial process shutdown of the
facility or system is required.
2. If a shutdown is not required then proceed to Step 3.
If a shutdown is required this shall have been planned in to the 90 day
‘Integrated Activity Plan’ and provisions made (deferment) for the loss in
production.
If the shutdown has not been planned then a ‘variance’ to the ‘Integrated
Activities Plan’ shall be required to be made. This shall require the correct
approvals and authorisations being obtained.

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CONFINED SPACE ENTRY PROCESS FLOW

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3. The ‘Permit Applicant’ shall complete the PTW and the Confined Space
Entry Certificate as required. Depending on the nature of the work to be
undertaken additional Certificates such as Mechanical 7 and Electrical
Isolation may be required.
4. The permit applicant and the ‘Responsible Supervisor’ shall inspect the
work site and identify all hazards. The permit applicant and responsible
supervisor shall produce and agree a Risk Assessment which will form the
basis of a ‘Job Safety Plan’ which shall be approved by the responsible
supervisor.
5. The responsible supervisor shall:
 authorise the PTW
 authorise the isolation on the Mechanical Isolation Certificate
 check the ‘Confined Space Entry Certificate’ safety precautions
(Section 2)
 approve the risk assessment and Job Safety Plan
6. Once authorised the PTW and all other required certificates shall be issued
to the ‘Permit Holder’ to undertake the work.
7. The area authority shall oversee or undertake the required isolation in
accordance with the mechanical isolation certificate and ensure that
electrical isolations have been made and certified by the competent
electrical person. The isolations shall be signed for on the PTW and / or the
Mechanical / Electrical Isolation Certificates.
8. The permit holder shall complete the TRIC and conduct a TRIC talk’ to
ensure that personnel working on the job are aware of the safety hazards,
the risk assessment contents, control measures required and emergency
response procedures.
The permit holder shall oversee the provision of all necessary safety
equipment and that the correct tools and PPE are provided.
9. The Area Authority shall check that all safety precautions have been taken
and that all required equipment for the confined space entry is available.
10. Once the PTW has been validated by the area authority the
vessel/tank/equipment can be drained, gas freed and opened for ventilation.
11. The initial gas test shall be taken when the confined space has been
ventilated or prepared for entry. When gas freeing using nitrogen has taken
place a meter capable of measuring hydrocarbons in an inert atmosphere
shall be used. The gas test shall be conducted by the area authority or
registered gas tester. The results are entered on the Confined Space Entry
certificate.
12. Once the gas tests have been conducted and the confined space conforms
to the requirement the authorisation can be issued by the responsible
supervisor / area authority. The authorising authority shall sign the
appropriate section of the Confined Space Entry certificate.

7
Isolations can be entered on the PTW, however if the isolation is complex a Mechanical
Isolation Certificate is used. This may be backed by additional documents if more space is
required.

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CAUTION: Before entry shall be authorised confined spaces that have

contained hydrocarbons shall be tested using a Photo-Ionization
Detector (PID – e.g. Dragger Tube) to confirm that levels Butane,
Pentane and Benzene (highly narcotic) are below OEL and % volume
required to produce surgical anaesthesia.
13. The work can be carried out within the confined space in accordance with
that defined on the PTW. The permit holder shall oversee the work and
ensure that ‘entries’ and ‘exits’ are logged on the Confined Space Entry
certificate.
The appointed ‘standby man/men’ shall maintain communication with the
personnel inside the confined space and also the area authority / CCR.
14. Additional gas tests (including PID if considered necessary) shall be carried
out in accordance with the PTW. These gas tests shall be entered at the
correct intervals on the Confined Space Entry certificate or the Additional
Gas test Records sheet.
15. On completion of the work the permit holder shall oversee the
‘normalisation’ of the work site. The confined space shall be inspected and
all ‘entry and exit’ records checked before closure is authorised. Inspection
and authorisation for closure shall be given by the area authority or
responsible supervisor.
16. On closure the Permit Holder carry out reinstatement testing of the
equipment / vessel and remove or oversee the removal of all isolations with
the Area Authority. The Area Authority shall be close out the PTW.
17. The vessel/tank/equipment shall be handed over to production and brought
back into service.

5. APPENDIX 1 – ABBREVIATIONS
Central Control Room
CCR
MCC Machinery Control Centre
ALARP As Low As Reasonably Practical
HSE Health Safety and Environment
LEL Lower Explosive Limit
PPE Personal Protection Equipment
PTW Permit to Work

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6. APPENDIX 2 – USER FEEDBACK PAGE

PR-1148 – Confined Space Entry User Feedback Page

Any user who identifies an inaccuracy, error or ambiguity is requested to notify
the custodian so that appropriate action can be taken. The user is requested
to return this page fully completed, indicating precisely the amendment(s)
recommended.
Name:
Ref ID Date:

Page Ref: Brief Description of Change Required and Reasons

Custodian of Document Date:

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