Title:

Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.:
PA-020-0052

Port Arthur, TX.

Reviewed:

Preparer:
EHS Team Member

01/12

Effective:

Owner:
EHS Team Member

Page:
06/15/08
(Rev.01)

1 of 17

Supersedes: 01/05/06
(New)
Approver:
EHS Manager

Document Revision Change Table

Revision
Number
01

Revision Description

Revised By

Changed Header and Footer

Procedure Reviewed (No Changes)
Reviewed No changes

VB
TF
TD

Revision
Date
06/08
12/08
01/12

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Title: Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.: PA-020-0052

Port Arthur, TX.

Reviewed: 01/12

Page: 2 of 17

Effective: 06/15/08 Supersedes:

(Rev.01)

01/05/06
(New)

1. PURPOSE
This policy establishes requirements for inert confined space entry for the NROC Site.
This policy will be used in addition to the Sites Confined Space Procedure (PA-0200004). An Inert Entry is required when removing or loading catalyst, packing or
desiccants that are pyrophoric in nature and could create a fire when coming in contact
with air.
2. DEFINITIONS
2.1.

Inert Entry Attendant

An individual stationed outside the confined space who monitors the Authorized
Entrants.

2.2.

Authorized Entrant
An individual who is authorized by the employer to enter a confined space.

2.3.

Confined Spaces
Spaces which can be bodily entered, have limited or restricted means of egress,
are not designed for continuous employee occupancy, and have one or more of
the following characteristics:

Contain or have the potential to contain a hazardous atmosphere (such as

having held flammable, explosive, acidic, caustic, toxic materials) or where
oxygen enriched or deficient atmospheres or noxious odors may exist.
Contain a material that has the potential for engulfing an entrant.
Have an internal configuration such that an entrant could be trapped or
asphyxiated by inwardly converging walls or by a floor which slopes downward
and tapers to a smaller cross-section.
Contain any other recognized serious safety or health hazards; such as
ionizing radiation, electric shock, temperature extremes, or moving parts.
Such spaces include, but are not limited to: tanks, tank trucks, tank cars, duct
work, vats, tubs, hoppers, bins, boilers, kilns, cooling towers, stacks,
chimneys, sewers, trenches, pits, manholes, elevated or ground flares, or
other similar equipment/structures. This may also include structures greater
than four feet in height, or excavation that are greater than four feet in depth
that have limited or restricted means of egress.

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Title: Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.: PA-020-0052

Port Arthur, TX.

Reviewed: 01/12

2.

Page: 3 of 17

Effective: 06/15/08 Supersedes:

(Rev.01)

01/05/06
(New)

DEFINITIONS contd.
2.4.

Immediately Dangerous to Life or Health (IDLH)

Any condition that poses an immediate or delayed threat to life or that would
cause irreversible adverse health interfere with an individuals ability to escape
unaided from a confined space. Included in this definition is an oxygen deficient
atmosphere containing less than 19.5 percent oxygen by volume. (Refer to the
NIOSH Pocket Guide to Chemical Hazards for IDLH limits for toxic chemicals)

2.5.

Entry Rescue
A confined space rescue that must be performed by having the rescue team enter
the confined space.

2.6.

Inert Entry
The action by which a person passes through an opening into a confined space
that has been filled or is filled with an inert gas such as nitrogen. This constitutes
a IDLH environment where proper set-up and execution of work and safety
systems is critical. At the Port Arthur Site, Inert Entries are used for the unloading
and loading of potentially pyrophoric catalyst, packing or desiccants. These
entries are done in nitrogen environments.

2.7.

Hazardous Atmosphere
An atmosphere that may expose employees to the risk of death, incapacitation,
impairment of ability to self rescue, injury or acute illness from one or more of the
following causes:
Flammable gas, vapor or mist in any detectable concentration using a calibrated
combustible gas indicator operating in the percent range of sensitivity.
Airborne oxygen concentration below 19.5% or above 21.0%.
Atmospheric concentration of any substance for which a dose or permissible
exposure limit is published in 29 CFR 1910 Subpart G, Occupational Health and
Environmental Control, or in Subpart Z, Toxic and Hazardous Substances, and
which could result in the employee exposure in excess of its dose or permissible
exposure limit.
Any other atmospheric condition that is immediately dangerous to life or health.

NOTE:
For air contaminants for which OSHA has not determined a dose or permissible exposure
limit, other sources of information; such as, Material Safety Data Sheets, ACGIH TLVs,
published information, and internal documents may provide guidance in establishing
acceptable atmospheric conditions.

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Title: Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.: PA-020-0052

Port Arthur, TX.

Reviewed: 01/12

2.

Page: 4 of 17

Effective: 06/15/08 Supersedes:

(Rev.01)

01/05/06
(New)

DEFINITIONS contd
2.8.

Entry Supervisor
The person responsible for determining if acceptable entry conditions are present
where entry is planned, for authorizing entry and overseeing entry operations, and
for terminating entry as required. At the Port Arthur Facility, the shift coordinator
normally acts as the entry supervisor, with the exceptions of plant turnarounds or
shutdowns when others may act in this capacity.

3.

SCOPE

4.

PROCEDURE
4.1.

Contractor Selection
The Texas Hubs Contractor Selection Procedure (EHS Texas Hub Procedure)
will be followed. For Inert Entry Contractors, the following additional
reviews/discussions are required in the areas of training, medical records,
procedures, equipment inspections and management commitment. The
contractor must demonstrate to BASF a clear commitment to Safety as a core
value and an ongoing cycle of continuous improvement. The following are key
components of this review process:
4.1.1. Conduct a detailed review of the training program during the initial review
of any Inert Entry Contractor considered for addition to the Approved
Contractor List. This review should include quality of training materials,
review of training records, instructor qualifications, and experience
requirements in each position. It is critical that specific personnel who will
carry out the inert entry have adequate training and experience.
4.1.2. All contractors that perform Inert Entry work must have their Safety
Program reviewed, including Inert Entry and Rescue Procedures, against
the key requirements of this document.
4.1.3. Review fit test records to ensure that personnel working in breathing air are
routinely examined for medical fitness as required by OSHA 29 CFR
1910.134.
4.1.4. Review inspection and test records for all breathing air equipment, Life
Support Systems, emergency rescue equipment and gas testing
equipment to ensure it is routinely inspected and tested.

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Title: Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.: PA-020-0052

Port Arthur, TX.

Reviewed: 01/12

4.

Page: 5 of 17

Effective: 06/15/08 Supersedes:

(Rev.01)

01/05/06
(New)

PROCEDURE contd
4.2.

Management Presentation
Management of contractors who perform Inert Entry work must make a
presentation to BASF Site Management prior to award of contract and annually
thereafter. The presentation should include, at a minimum:
4.2.1. Demonstration of Management Commitment to Safety
Senior Management Site Visits for sole purpose of EHS review
Company Organizational Chart Review
Organizational Roles & Responsibilities
4.2.2. Environmental, Health and Safety Program Review
Equipment Program (Inspection, Replacement/Upgrade
Personnel (Training, Experience, Crew Size)
Company History (Experience in Type and Scope of job)
Auditing (Pre-Job, Execution, Follow-up Actions)
Job Observation Program
Hazard Recognition Program
Incident Investigation and Follow-up (Review of contractor incidents
with changes implemented & corrective action closure times.)
Three year history of near miss incidents
Three year history of Safety Statistics

4.3.

Pre-Job Planning
Because of the critical nature of inert entry, it is important that both BASF and the
contractor work together. Each party has critical tasks they must complete prior to
starting the inert entry. Pre-planning every aspect of the job is required in order to
complete the job successfully.
Company Management
Although a qualified contractor will perform the inert entry, BASF employees must
be involved in the operation to provide the contractor with the proper facility
knowledge, job expectations and accountability to complete the job safely.
4.3.1. Contractors written site safety and emergency/rescue plan will be reviewed
by Shift Coordinator, Area Team Lead and Site EHS personnel before the
start of work.

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Title: Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.: PA-020-0052

Port Arthur, TX.

Reviewed: 01/12

4.

Page: 6 of 17

Effective: 06/15/08 Supersedes:

(Rev.01)

01/05/06
(New)

PROCEDURE contd
4.3.

Pre-Job Planning contd

4.3.2. Prior to inert entry, the Area Maintenance Coordinator will coordinate a
meeting to discuss the contractors written plan for performing work under
inert conditions. Meeting attendees shall include:

Shift Coordinator
Area Team Lead
Contractor Safety Representative
EHS Representative
Contractor Foreman
Area Operations Coordinator
Area Operations Technician

Results of this meeting shall be documented and action items must be

completed prior to start of the inert entry job.
4.3.3. A BASF representative is required to be in the entry area throughout the
inert portion of the entry job. Extra coverage will be scheduled if necessary
to comply with this requirement.
4.3.4. Air Supply must be Certified Grade D quality breathing air. A quality
control check will be made by On-Site Safety Store personnel as the
bottles are brought to the Site. The bottles will be individually tested and
tagged.
4.3.5. Blended or synthetic air will NOT be used for supplied breathing air used
by employees or contractors.
Contractor
Written Documentation
Contractor must provide to BASF representative written documentation prior to
commencement of work supporting qualifications for working in an inert
environment. The minimum documentation required should include:
4.3.6. Employee service and current training records for all crew members.
4.3.7. Certification of emergency/rescue training.

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Title: Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.: PA-020-0052

Port Arthur, TX.

Reviewed: 01/12

4.

Page: 7 of 17

Effective: 06/15/08 Supersedes:

(Rev.01)

01/05/06
(New)

PROCEDURE contd
4.3.

Pre-Job Planning contd

4.3.8. Documentation of Confined Space Entry training consistent with OSHA 29
CFR 1910.146.
4.3.9. A written procedure for performing work.
4.3.10. A written emergency plan to include, but not limited to:
Loss of N2 supply
High N2 pressure
High equipment O2
High equipment temperature
Loss of Breathing Air Supply
Emergency inside the reactor/dryer
Plant Emergency outside of the reactor/dryer
4.3.11.
4.3.12.

Heat Stress Plan

Contractor must provide written program for control of heat stress, such
as work/rest regimens, monitoring workers and use of auxiliary cooling.
Job Safety Analysis
The contractor must prepare a JSA, which is specific to the vessel
being entered and the work being undertaken. The JSA needs to
address all the risks associated with the work such as:
Setting up the inert entry and catalyst handling equipment at the
work site
Access and egress to the equipment
Provision for adequate lighting
Control of access around the work site and around any open
manways where nitrogen is being vented
Lifting and rigging activities
Manual handling activities
Catalyst handling
Removal of vessel internals (if required)
Catalyst loading
Installation of warning signs utilizing international caution/danger
symbols

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Title: Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.: PA-020-0052

Port Arthur, TX.

Reviewed: 01/12

4.

Page: 8 of 17

Effective: 06/15/08 Supersedes:

(Rev.01)

01/05/06
(New)

PROCEDURE contd
4.3.

Pre-Job Planning contd

4.3.13.

Contractors Equipment
Inert entry requires specialized equipment that must be inspected and
in good working order. Contractors must supply the equipment
necessary for completing the job.
Contractors must maintain a communications system for use by the
employees working inside the inert atmosphere and those
monitoring the work from the outside. This system must be capable
of simultaneous communication with all connected personnel and
must include a redundant system in the event the primary system
fails.
Entrants can be lowered into the vessel using a winch/hoist
specifically designed for carrying people. A ladder can be used for
access as well if it meets Site Standards found in PA-020-0013.
All hand tools contractors bring on Site will be in good workable
order. All designed safeguards will be remain in place and not
tampered with or bypassed.
Inherent Safe Connections will only be used.
Labeling of all air and communications lines will be required.
Any pneumatic equipment used inside the confined space will use
nitrogen as the energy source.

4.3.14.

Personal Protective Equipment

A risk assessment should be conducted to determine the additional
PPE required to protect the persons working inside the equipment from
catalyst dust, any residual oil and any physical hazards.

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Title: Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.: PA-020-0052

Port Arthur, TX.

Reviewed: 01/12

4.

Page: 9 of 17

Effective: 06/15/08 Supersedes:

(Rev.01)

01/05/06
(New)

PROCEDURE contd
4.3.

Pre-Job Planning contd

4.3.15.

Life Support Systems

Two independent sources of air must be provided to a Helmet. The
secondary air supply should cut-in automatically whenever the
primary source is overextended or over breathing occurs.
The entrant must wear an auxiliary escape air bottle.
An Emergency Egress Line shall be supplied for each entrant for
emergency egress. Air for these Emergency Egress Lines shall be
supplied from an independent source.
The helmet must be sufficiently secured to prevent inadvertent
removal. The helmet must be in clean, workable order with all
inspections complete and documented.
The umbilical cord containing the air hoses must be adequately
sheathed to protect the hoses and be designed such that the hoses
cannot be detached should the umbilical cord be pulled or snagged.
A trained attendant, located outside the confined space, must
continuously monitor the air supply. An alarm, audible/visible, shall
be provided to warn of low air pressure. An alarm will also be
required to warn when secondary air has been activated.
If for any reason the primary communication link fails, the persons
working inside must be evacuated. BASF personnel will also be
notified.
The entrant working inside the vessel must be in visual contact of
the attendant. An additional standby may be necessary in addition
to other visual means such as CCTV.

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Title: Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.: PA-020-0052

Port Arthur, TX.

Reviewed: 01/12

4.

Page: 10 of 17

Effective: 06/15/08 Supersedes:

(Rev.01)

01/05/06
(New)

PROCEDURE contd
4.3.

Pre-Job Planning contd

4.3.16.

Rescue/Evacuation
Adequate emergency rescue facilities should be immediately available
at the vessel manway and the contractors should be trained in its use.
This should include:
Hoisting device and wire lifeline to extract person from the inside of
the confined space.
Persons working inside the vessel should wear a harness
(Shoulder D Ring Type), which enables the person to be lifted out
of the vessel in a vertical position.
A pre-planned means of lowering the person to the ground. (stokes
basket)
A radio or other means of summoning assistance.
The attendant at the vessel must wear standard inert entry
equipment so that in an emergency they can enter the vessel to
assist the injured person. A spare set of standard inert entry
equipment must be available at the vessel manway so that another
technician can replace the safety standby.
Trained personnel to provide emergency first aid and
cardiopulmonary resuscitation (CPR)

4.3.17.

When to Evacuate
An evacuation of the vessel must occur under the following
circumstances:
Loss of primary communications systems
Vessel temperature rise greater than 15 deg. F.
Loss or problems with primary air
Loss or problems with nitrogen purge
Loss of power and/or lighting
O2 concentration greater than 4%
Whenever the Sites Emergency Horn goes off (with the exception
of the weekly test that occurs every Monday at noon).
Use of emergency egress bottle
Anytime a vessel is evacuated, a thorough investigation must be
performed to identify the cause(s) that led to the condition requiring
evacuation. Entry shall not be permitted back into the space until
corrective actions have been implemented to address the cause(s).
The inert entry permitting process should be repeated and a new entry
permit issued.

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Title: Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.: PA-020-0052

Port Arthur, TX.

Reviewed: 01/12

4.

Page: 11 of 17

Effective: 06/15/08 Supersedes:

(Rev.01)

01/05/06
(New)

PROCEDURE contd
4.3.

Pre-Job Planning contd

4.3.18.

Process/Operations
There must be a primary (truck/trailer) supply and secondary nitrogen
(plant N2) supply to the vessel. The primary trailer supplying the
nitrogen must be backed up by a second trailer that is staged on site.
In the event that a nitrogen trailer runs empty, operations will switch
over to the secondary plant nitrogen system until a trailer swap is
accomplished. O2 and temperatures should be watched carefully
during this time. Ideally there will be two nitrogen trailers on site at all
times with a third trailer being in transport between the Site and the
Nitrogen fill facility.

Due to the potential for some catalyst to develop crust, planning the
introduction of nitrogen supply must address methods to eliminate
the potential for build-up of pressure below this crust.

Operations personnel preparing the job will perform atmospheric

testing to determine a safe zone. The area around the Inert Entry
Operation will then be barricaded to limit personnel in the area.

Warning signs should be posted at the point of access to the area

(ladder cage, elevator, etc.) and the entry point. These signs
should readIDLH Entry In Progress! Do not enter without
operations approval!

All open manways must be covered or otherwise protected from fall

hazards.

Operations must tag all valves in the N2 system to indicate OPEN

or CLOSED position. Tags should be weatherproof and be secured
with a tie wrap.

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Title: Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.: PA-020-0052

Port Arthur, TX.

Reviewed: 01/12

4.

Page: 12 of 17

Effective: 06/15/08 Supersedes:

(Rev.01)

01/05/06
(New)

PROCEDURE contd
4.4.

Field Execution
4.4.1. Pre-Job Checks
Prior to beginning the inert entry, a Pre-Job check is completed to ensure
all planning activities, meeting action items, emergency and rescue plans
have met BASF requirements. This step is to ensure all equipment is in
place, to make final checks of the job, and be sure the space and
personnel are prepared to complete the job safely. The following are key
components of a facility programs related to field execution:

Permit issuers must test all areas around the openings to determine
boundaries of regulated areas. The boundaries will be barricaded
to ensure non-entry personnel do not enter oxygen deficient
environments.
Open manways must be secured to prevent fall hazards.
Any deviations from the Confined Space Permit or Inert Entry
Procedure must be documented and signed off by appropriate
personnel.

4.4.2. PPE
The PPE hazard assessment completed during the planning phase should
clearly identify the PPE required for all task being performed during each
specific inert entry operation. Contractor supervision must enforce the
implementation of the requirements identified by the Safe Work Permit.
BASF will also audit the use of required PPE.
4.4.3. Emergency Plan Verification
The emergency plans developed during the planning phase must be
verified to ensure they are in place and all members of the rescue team
understand their roles and responsibilities under these plans. It is equally
important that entrants, attendants, support personnel and all employees
involved in an inert entry know what to do in the event of an emergency.

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Title: Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.: PA-020-0052

Port Arthur, TX.

Reviewed: 01/12

4.

Page: 13 of 17

Effective: 06/15/08 Supersedes:

(Rev.01)

01/05/06
(New)

PROCEDURE contd
4.4.

Field Execution contd

4.4.4. Entry Conditions
Vessel atmosphere requirements for inert entry with life support system
breathing apparatus are outlined in the following table. If these levels are
exceeded while an entry is in progress, the vessel must be evacuated until
these levels are restored:
Substance
Oxygen

Max Value
4%

Hydrocarbons

0%

H2S

10ppm

Benzene

1ppm

CO

50ppm

Comment
The max limit set by
API 2217A is 5%. The
maximum limit for
vacuum operations is
2%. This provides
time for emergency
action to be taken.
This to be determined
on a case by case
basis depending on
the individual job and
circumstances.
Limit based on
avoiding H2S levels
>10 ppm in the vicinity
of the reactor manway
platform.
Limit based on
avoiding benzene
levels >1 ppm in the
vicinity of the reactor
manway platform.
Should be tested when
catalyst contains
Nickel or Cobalt. This
is to prevent the
potential of highly toxic
metal carbonyls.

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Title: Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.: PA-020-0052

Port Arthur, TX.

Reviewed: 01/12

4.

Page: 14 of 17

Effective: 06/15/08 Supersedes:

(Rev.01)

01/05/06
(New)

PROCEDURE contd
4.4.

Field Execution contd

4.4.5. Ongoing Monitoring
Contractor
In order to maintain a safe environment, the contractor should maintain a
periodic log or checklist of continuous monitoring. BASF personnel will
periodically audit these readings. The checklist or log must included:
Vessel Temperature
LEL
Oxygen Concentration
Air Supply (Primary & Secondary) Checks
Communication Checks
Operations
Area operations technician will be responsible for maintaining a safe
working environment. Responsibilities include:
Audit of contractors to ensure ongoing monitoring is taking place
Contact will BASF board technicians to ensure temperatures and
other variables are maintaining
Performing LEL/O2 readings determined by permit requirements
Personal presence in the area of Inert Entry
Issuance of all permits required for work being performed
Ensuring adequate nitrogen flow is maintained
Informing contractors of any emergency situations
Ensuring company LEL meters are checked by bump testing at
least once per shift

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Title: Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.: PA-020-0052

Port Arthur, TX.

Reviewed: 01/12

4.

Page: 15 of 17

Effective: 06/15/08 Supersedes:

(Rev.01)

01/05/06
(New)

PROCEDURE contd
4.4.

Field Execution contd

4.4.6. Vacuum Operations
Vacuum operations can present additional and unique hazards during inert
entry. The nature of the operation can affect the atmosphere in the vessel
and present new physical hazards in and outside the space. These risks
must be addressed from the approval process through execution. The
following additional precautions need to be taken:
All components including the ducting, the cyclone and vacuum
equipment must be properly bonded together and must be
grounded to prevent build-up of an electrostatic charge.
Hoses can be eroded by catalyst and must be visually examined
prior to each use.
Vacuum equipment must be purged with nitrogen prior to use and a
nitrogen supply should remain connected at all times.
A vacuum system removes large amounts of nitrogen from the
vessel. Nitrogen levels in the vessel must be regulated to maintain
the proper concentration during vacuum operations. Exhaust
should be discharged to a safe location. A barricade should be
utilized to establish a safe zone around the vacuum truck.
Vacuum operations must be stopped if the vessel O2 level rises
above 4%.
The location of the vacuum hose could hamper emergency egress
from the vessel. This needs to be considered in the emergency
evacuation procedures.
Spent catalyst containers must be inerted before being loaded.
At the end of the vacuuming operation, the internal components of the
vacuum system should be thoroughly washed/cleaned to remove
pyrophoric dust/residues. Filters should be routinely cleaned to prevent
build-up of pyrophoric waste.

4.5.

Post Job Critique

At the conclusion of each inert entry job, there shall be a documented critique
facilitated by BASF Operations/Maintenance/EHS Teams and the Inert Entry
Contractor. The agenda for the critique shall include:
Contractor review of Highlights and Opportunities
Company review of Highlights and Opportunities
Review of evacuations that were required and corrective actions
Review of all audits performed during the job
Review of all near misses and corrective actions
Lessons learned

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Title: Inert Confined Space Entry

Individual Unit
Procedure

Function: Health and Safety

No.: PA-020-0052

Port Arthur, TX.

Reviewed: 01/12

5.

Page: 16 of 17

Effective: 06/15/08 Supersedes:

(Rev.01)

01/05/06
(New)

RESPONSIBILITIES
5.1.

Port Arthur Site Leadership Team

Has primary responsibility for implementation of this procedure.

5.2.

Environmental, Health, and Safety Manager

Has primary responsibility for the initiation, re-issuance, administration, and/or
interpretation of this procedure.

5.3.

Port Arthur Employees and Contractors

Have primary responsibility for adherence to procedure including identifying
deficiencies in the procedure, and identifying, reporting and correcting activities
not in compliance with the procedure

6. RELATED DOCUMENTS
BC032.017 Confined Space Entry
29 CFR 1910.146 Confined Space Entry
Health & Safety Procedure PA-020-0004 Confined Space Entry
Health & Safety Procedure PA-020-0017 Personal Protective Equipment
Health & Safety Procedure PA-020-0013 Ladders
Attachment A Area Technician Checklist

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PA-020-0052

Attachment A

Area Technician Checklist

Area Technician

Effective:06/15/08

Time

Date

Entry Contractor
Safety Checks
Current &
Updated?

Area
Housekeeping
Acceptable?

Approved by: EHS Manager