As the Risk Control Manager for an oil refinery, one is tasked to prepare a safety plan for refinishing the interior of a 200,000 gallon fuel tank. The scope of the work includes painting the interior of the fuel tank and welding some broken legs on the floating roof. The safety plan is hereby presented with the focus of information to include: confined space entry, ventilation, and personal protective equipment (PPE).
Policy or goals statement
The objective is to successfully undertake two (2) relevant tasks: (1) painting the interior of a 200,000 gallon fuel tank; and 92) welding some broken legs on the floating roof. The goal is to be able to complete these tasks with zero injuries, accidents, or fatalities.
List of responsible persons
The tasks would be undertaken by four (4) people: two (2) individuals would be in charge of painting the 200,000 gallon fuel tank, while two (2) persons would weld the broken legs on the floating roof. The risk control manager would oversee and administer compliance of these tasks. The risk manager identifies the hazards and proposes hazards control and safe practices.
There are hazards identified in painting the 200,000 gallon fuel tank pertinent to confined spaces, as noted herewith:
limited entry and exit which could expose the painters to oxygen deficiency;
since it is a fuel tank, there could still be presence of flammable materials;
the paint and painting accessories could contain chemicals which could pose exposure to fire and/or explosion
ventilation should be monitored to ensure protection from harmful gases
asphyxiation/suffocation due to engulfment
Risks for fire or explosion due to the presence of flammable materials;
Potentials for exposure to oxygen deficiency;
Propensities for electric shock, bright light, ultraviolet radiation
Ergonomic issues and noise
Hazard controls and safe practices
The general requirements to ensure safety in confined spaces include adherence to standards for the following main tasks: (a) safe entry policy and procedure; (b) securing the needed permits (permit to entry and permit to work); (c) testing of the atmosphere; (d) checking for ventilation issues; and (e) use of PPE . These sections are expounded as follows:
(a) Safe entry policy and procedure;
Conduct a meeting with the painters and welders prior to undertaking the tasks to discuss and orient them on safety measures, policies, and procedures.
Ensure that the fuel tank is free from flammable materials.
Check the ventilation in the fuel tank.
Check for any possible sources of leaks or connection to other tanks which could have flammable materials.
Check for the need to isolate the fuel tank.
Prepare and assign a stand-by rescue team.
Install the needed lighting to undertake the task effectively.
Install safety harness, ladders, and other safety rescue equipment, as deemed needed.
Identify the specific PPEs that are needed in the undertaking of the task.
(b) Securing the needed permits (permit to entry and permit to work)
Secure the needed permit to entry and permit to work.
As emphasized, the permit to work provides details on the following:
“set out the work to be done, the location and the precautions to be taken;
predetermine safe methods of work;
provide a clear record that all foreseeable risks have been considered;
define the precautions to be taken and their sequence;
provide written authority for the confined space to be entered and the work to start and the time when the work must cease”
Install warning signs with appropriate labels and posted according to standards
(c) Testing of the atmosphere;
Test for oxygen deficient or oxygen enriched atmospheres using defined standards, as follows:
“normal = 20.8%
deficient < 19.5 %
enriched > 23.5%” .
Test of flammable atmosphere using defined standards:
“A space with an atmosphere with more than 1% of the “Lower Flammable Limit” (LFL) or “Lower Explosive Limit” (LEL), on a combustible gas indicator should not be entered.
The Flammability indicator shows the percent within a safety range of 0-10% of the Lower Explosive Limit (LEL) and, ideally, should read 0%. Combustible gas detectors have normally two measuring ranges 0-100% LEL and 0-10% LEL”
Test for toxic atmosphere, according to the following time limits:
Source: IACS, 2007, p. 7
(d) Checking for ventilation issues;
Ensure that the fuel tank has been ventilated prior to entry;
Determine needed ventilation during the painting process;
As emphasized, follow the OSHA standards, to wit:
“1915.35(b)(1): Sufficient exhaust ventilation shall be provided to keep the concentration of solvent vapors below ten (10) percent of the lower explosive limit. Frequent tests shall be made by a competent person to ascertain the concentration.
1915.35(b)(2): If the ventilation fails or if the concentration of solvent vapors reaches or exceeds ten (10) percent of the lower explosive limit, painting shall be stopped and the compartment shall be evacuated until the concentration again falls below ten (10) percent of the lower explosive limit. If the concentration does not fall when painting is stopped, additional ventilation to bring the concentration to below ten (10) percent of the lower explosive limit shall be provided.
1915.35(b)(3): Ventilation shall be continued after the completion of painting until the space or compartment is gas free. The final determination as to whether the space or compartment is gas free shall be made after the ventilating equipment has been shut off for at least 10 minutes” .
(e) Use of PPE
Ensure the availability of required PPEs for the painters: “all footwear shall be non-sparking, such as rubbers, rubber boots or rubber soled shoes without nails. Coveralls or other outer clothing shall be of cotton. Rubber, rather than plastic, gloves shall be used because of the danger of static sparks” .
Other identified PPEs include: air line respirators and/or filter cartridge type respirators .
For welders, other PPEs include: eye protection (goggles), helmets and hand shields, and other safety shields .
Emergency and accident response
For emergency situations, immediately call 9-11.
Ensure that the emergency rescue team provides the needed emergency procedures, depending on the injuries that were sustained.
The emergency response plan pertinent to the tasks would be consistent with the plan prepared for the organization .
Personnel training and communication
All personnel (painters and welders) should be properly trained on safety policies and procedures, as well as in hazards identification and application of control measures. Likewise, communication protocols in emergency and accident response are indicated above.
Control measures include engineering controls (use of PPEs), administrative and management control (safety policies and procedures), as well as performance monitoring through presence and observing compliance to standards while undertaking the needed tasks. Likewise, as risk control manager, one would have to schedule undertaking these tasks, as welding and painting done simultaneously could pose additional hazards in the environment.
Canadian Center for Occupational Health and Safety. (2010, December 1). Welding - Overview of Types and Hazards. Retrieved from ccohs.ca: http://www.ccohs.ca/oshanswers/safety_haz/welding/overview.html
Chauhan, N. (2013). Safety and Health Management System in Oil and Gas Industry. WIPRO.
Confined Space. (2015). Power Point Presentation.
IACS. (2007, April). Confined Space Safe Practice. Retrieved from iacs.org.uk: http://www.iacs.org.uk/document/public/publications/guidelines_and_recommendations/pdf/rec_72_pdf212.pdf
OSHA. (n.d.). Painting. Retrieved from osha.gov: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10227
OSHA. (n.d.). Welding, Cutting, and Brazing . Retrieved from osha.gov: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=9853&p_table=STANDARDS
Personal Protective Equipment. (2015). Power Point Presentation.