HSS-104 Confined Spaces v1.0

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Confined Spaces

HSS-104

Issue Date: February 1, 2018


Effective Date: February 1, 2018
Version: 1.0

LafargeHolcim Group Health and Safety


Corporate Office, Paris, France
Confined Spaces
HSS-104

Contents
1. Purpose .......................................................................................................................................... 3
2. Scope.............................................................................................................................................. 3
3. Program Management .................................................................................................................. 3
4. General Requirements .................................................................................................................. 4
4.1. Hazard Identification and Procedure Creation...................................................................................... 4
4.2. Entry Permit (Permit to Work) .............................................................................................................. 5
4.3. Operational Controls ............................................................................................................................. 5
4.3.1. Access Controls ........................................................................................................................... 5
4.3.2. Atmospheric Controls ................................................................................................................. 5
4.3.3. Fire and Explosion Controls ........................................................................................................ 6
4.3.4. Liquids and Free-flowing Solids Control ..................................................................................... 6
4.4. Hazard Communication ......................................................................................................................... 7
4.5. Emergency Controls .............................................................................................................................. 7
5. Worker Health and Safety............................................................................................................. 7
5.1. Health .................................................................................................................................................... 7
5.2. Prohibited Behaviours ........................................................................................................................... 7
6. Management of Change................................................................................................................ 7
7. Training, Competency and Authorization ................................................................................... 8
7.1. Roles Relating to Confined Space Entry ................................................................................................ 8
7.1.1. Confined Spaces Entry Permit Issuer .......................................................................................... 8
7.1.2. Attendant ................................................................................................................................... 8
7.1.3. Entrant ........................................................................................................................................ 8
7.2. Training Delivery ................................................................................................................................... 9
8. Record Retention .......................................................................................................................... 9
9. Document Control ....................................................................................................................... 10
Appendix 1- Definitions ...................................................................................................................... 11

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Confined Spaces
HSS-104

1. Purpose
The purpose of this standard is to communicate LafargeHolcim Group’s minimum health and safety
requirements for managing the risks associated with entry into and work within confined spaces.

2. Scope
This standard applies to all Confined Spaces (CS) and activities within them that take place while
under LafargeHolcim management control.

The Country must develop and publish its own local standard that complies with this Group Standard,
local legislation and any other standards, regulations or other requirements to which the Country has
committed to.

Where the requirements of local legislation are more stringent than those specified in this standard,
then the local legislation must be complied with.

3. Program Management
The Country and its Units must document and implement a program that establishes:

a) A Country specific standard for confined spaces.


b) Templates for confined space work procedures and any associated checklists and record forms.
c) A process for identifying and assessing confined space hazards and selecting appropriate risk
controls.
d) A process for authoring and publishing confined space procedures, including version control and
accessibility.
e) Documented roles and responsibilities (including authorizations and authorities).
f) A process for ensuring that equipment procurement and commissioning complies with the
requirements in this standard.
g) Practical and theory training specifically tailored for the following roles:
g.1. Those who develop confined spaces procedures.
g.2. Those who have the authority to issue confined space entry authorizations – Confined
Spaces Entry Permit Issuer.
g.3. Those who attend confined space working, monitor activity, and establish and secure
communications – Attendant.
g.4. Those who enter into and work within confined spaces – Entrant.
g.5. Those who, after assessment of competency, formally authorize workers to carry out
confined spaces activities (note: this is not the authorization to enter a confined space).
g.6. Those with authority to supervise confined spaces activity
h) A process to manage changes relating to confined spaces and confined space working.
i) Procedures to manage foreseeable confined space work related emergencies.
j) An initial and then annual review and gap analysis of the program and its procedures conducted
via procedure audits to:
j.1. Verify that compliance is being achieved.
j.2. Evaluate the effectiveness and relevance of confined space procedures.
j.3. Verify that management of change has been applied.
j.4. Create an action plan (or update the existing one) to eliminate, or where not practicable,
reduce the risks through the hierarchy of control.

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Confined Spaces
HSS-104

j.5. Document any deviation from minimum requirements, rules and prohibitions listed in this
Group Standard. Those deviations are to be limited to rare exceptions and are only
acceptable in extenuating circumstances when there is no practical way to be in compliance.
In such cases, the country must document the conflict and a formal specific procedure with
alternative controls must be in place including approval by Country CEO and Group H&S.

4. General Requirements
4.1. Hazard Identification and Procedure Creation
a) A competent person must identify the hazards associated with entry and working in a confined
space, or any job task that has the potential to create a confined space, and assess the risks and
then eliminate or control those risks that have the potential to result in harm to people involved.
b) A register of confined spaces must be maintained at each site. The register must be reviewed
and updated immediately after identification of new confined spaces and, in any case, no less
frequently than every 2 years. It will record the following:
b.1. A unique identifier for each confined space.
b.2. The location of each confined space.
b.3. The hazards that make the space a confined space (based on the confined space definition)
b.4. The register must also identify enclosed spaces within which activities are likely to be carried
out that change the status of the enclosed space into a confined space while the activity is
being carried out.
c) Documented job specific procedures must be written for confined spaces related activities, that
consider the following as a minimum:
c.1. Identity of the confined space.
c.2. The controls that must be in place before entry is allowed, including:
c.2.1. The acceptable levels for atmospheric conditions.
c.2.2. Ventilation requirements where harmful atmospheres are likely.
c.2.3. The method for testing and control of harmful atmospheres before and during entry.
c.2.4. Verification of equipment maintenance, testing and calibration.
c.2.5. Fire-fighting equipment when combustible or flammable substances/materials are
present.
c.3. Limitations to work activity within the confined space such as, but not limited to, working time
limits and temperature limitations.
c.4. Energy sources that must be isolated before entry into the confined space.
c.5. Procedures for hot working or any other activity that introduces a hazard.
c.6. Required lighting levels and the provision of additional suitable lighting.
c.7. Competencies required to enter the confined space and for any related work activities.
c.8. Normal method of entry and exit.
c.9. Method of 2-way communication between the Attendant and the Entrant (s).
c.10. Required PPE to be worn. Refer to HSS-003 Personal Protective Equipment Standard.
c.11. Requirement to wear a lifeline attached to a full body harness and anchored to the outside
of the space.
c.12. Emergency rescue plan
d) For every activity that has the potential to create a confined space (due to the nature of the
activity in combination with it being carried out inside an enclosed space) the procedure for that
activity must include:
d.1. A warning that the activity creates a confined space when carried out in an enclosed space.

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d.2. The requirement to implement a Permit-To-Work when those activities are planned for
enclosed spaces.

4.2. Entry Permit (Permit to Work)


a) Entry into a confined space must only be allowed when:
a.1. no alternative options for performing the job (i.e. doing the work from outside the space) are
practicable.
a.2. an entry permit has been issued and signed by the Confined Spaces Entry Permit Issuer
(CEPI).
b) The Unit manager must formally authorize work in high-risk confined spaces, in particular, but not
limited to, in:
 Silos.
 Storage tanks that previously contained fuels or toxic chemicals.
 Underground sewers.
 Excavations deeper than 2m.
c) Entry permits must not be issued for more than one shift. If the duration of the task/activities
cannot be completed within the shift, a new Entry Permit must be issued at the commencement of
the next shift.
d) Where a new shift takes over, the outgoing CEPI must hand over to the incoming CEPI.
d.1. All open Entry Permits must be closed out and new entry permits issued.
d.2. Workers must be briefed on the work completed, and the work that remains to be done.
d.3. All isolations must be managed according to the Energy isolation Standard.
e) If the scope of work for which the Entry Permit was issued changes, all work within the space
must cease until a new permit is issued.
f) The CEPI must physically inspect the work area to verify that all necessary entry requirements
have been met before approving the entry permit.
g) Upon task completion, the CEPI must verify that all entrants have vacated the space before
authorizing normal operations to resume.

4.3. Operational Controls


4.3.1. Access Controls
All access points must be locked to prevent unauthorized entry when the confined space is
unoccupied. If locking is not practicable, the condition must be documented in the confined spaces
register and that condition must be formally authorized by the Unit Manager.

4.3.2. Atmospheric Controls


4.3.2.1. Ventilation

a) Atmospheres that are hazardous must be ventilated to ensure a safe atmosphere before entry
and during the work activity if the hazardous atmosphere is likely to return.
b) The change rate for on-going ventilation must be no less than 20 times per hour.
c) Atmospheric sampling must be taken after ventilation to confirm that ventilation has worked
effectively.
d) Where ventilation is not practicable, then alternative methods of providing workers with a safe
breathable atmosphere must be implemented.
e) When Self-Contained Breathing Apparatus (SCBA) are used:
e.1. SCBA and airlines must be professionally manufactured and maintained.
e.2. Airline supplies must be regularly tested for air quality.

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e.3. A process for face-fit-testing of respirators and breathing equipment must be in place.
e.4. A policy on facial hair must be in place that ensures that SCBA will work effectively.

4.3.2.2. Gas Detection

a) The atmosphere of a confined space must be analysed prior to entry using equipment of sufficient
sensitivity and specificity to identify and evaluate any hazardous atmospheres that may exist or
arise.
b) Initial atmospheric testing shall be performed with ventilation systems shut down then in operation
to ensure they are not a possible source of contamination.
c) Results of testing must be recorded on the entry permit.
d) If the confined space is vacated for any reason, testing must be repeated, and results recorded
again on the entry permit, before entry is allowed again.
e) If the work performed within the confined space, or the nature of the confined space, could create
hazardous atmospheric conditions, continuous testing must be performed for the duration of the
activities.
f) Measurement for each atmospheric parameter must be conducted according to the instructions
provided by the sampling device manufacturer.
g) When monitoring is being done for entries involving a descent into atmospheres that may be
stratified, the atmospheric envelope must be tested at a distance of approximately 4 feet (1.22 m)
in the direction of travel and to each side.
h) Where a confined space is entered routinely and frequently, a fixed gas detection system must be
installed.
h.1. The display of fixed detection must be outside of the confined space.
h.2. Warning alarms must be located within the confined space and outside of it.
h.3. Alarms must be designed to be clearly heard throughout the confined space.
h.4. Alarms must be tested in compliance with the manufacturer's requirements.
i) Where it is not practical to install a fixed detection system, portable detection devices must be
used.
j) Detection systems must be maintained in good condition, calibrated in compliance with the
manufacturer's requirements and tagged with the next calibration date.
k) Gas monitors used in flammable atmospheres must be intrinsically safe.

4.3.3. Fire and Explosion Controls


a) The confined space must be isolated from any possible entry of flammable liquid or gas.
b) Condition and leak testing must be carried out on any pipe carrying flammable liquid or gas that
passes through a confined space.
c) Flammable or explosive substances/gases/vapour/mist must be removed by ventilation or dilution.
d) Sources of ignition must be eliminated or properly controlled.

4.3.4. Liquids and Free-flowing Solids Control


Where persons within a confined space could be engulfed or submerged by liquids or free-flowing
solids, controls must be in place to:

a) Isolate the supply of such liquids/solids to prevent further ingress


b) Remove the liquid/solids from within the confined space or if this is not practicable, reduce it to an
acceptable level.
c) Follow the requirements for ventilation if the liquid/solid creates a harmful atmosphere
d) Prohibit standing below the level of the substance/material (including blockages or build-up)

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4.4. Hazard Communication


A warning sign (e.g. “Warning- Confined Space- Enter by Permit Only”) must be displayed at each
entry point to a confined space (e.g. by every door and every access hatch).

4.5. Emergency Controls


For every confined space activity, an emergency procedure for rescue (rescue plan) must be
prepared and communicated, including:
a) Identity and contact details of authorized rescue personnel/services.
b) Method of rescue and required equipment. Priority must be given to non-entry rescue techniques
versus entry rescue.
c) Rules for the entry into the confined space for emergencies.
d) Method of reporting and recording an emergency incident.

5. Worker Health and Safety


Workers engaged in confined space activity must comply with planned working hours, rest breaks and
daily and weekly rest periods.

5.1. Health
a) An occupational health assessment of fitness for duty must be conducted pre-placement and at
least every 2 years for workers who enter confined spaces.
b) Workers must be advised during training programs to notify their supervisor if they develop a
health condition or start medication that may affect their fitness for duty so that they can be
referred to the occupational health service for assessment before entry into a confined space.
c) Requirements must be established for:
c.1. An occupational health assessment program for workers that work in confined spaces,
including formal reporting to management of fitness for duty outcomes after each
assessment.
c.2. Specific tests for workers authorized to use Self-Contained Breathing Apparatus (SCBA).
c.3. Rules to manage fatigue, including stipulating the maximum hours that worker can work in
the confined space and, the required daily rest breaks and daily and weekly rest periods.

5.2. Prohibited Behaviours


a) Entry into a confined space when not authorized
b) Allowing any other person to enter a confined space without the proper authorization
c) Not reporting confined space working incidents to a supervisor.

6. Management of Change
a) Any installation or modification of confined spaces and any change of work environment where
confined space working is to be carried out must trigger:
a.1. Review of applicable procedure(s) , including permit to work, and controls
a.2. Update of procedures and controls where they are found to be no longer valid or ineffective.
a.3. Communication about the change to all relevant workers.
b) Where new plant/equipment or buildings are to be constructed/installed, the design phase must
include a documented design review that identifies ways to eliminate, or where this is not
possible, to reduce the risks associated with confined spaces.

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HSS-104

c) The changes to procedures or working methods must also consider the need for new WaH
equipment and the associated training on the changes and or familiarization with the changes.

7. Training, Competency and Authorization


a) Confined space tasks/activities must be managed by using a competency and training matrix that
explicitly states the required competency and training for both workers and their supervisors.
b) Procedures must be in place to ensure that workers who carry out confined space activities are
formally authorized for those activities.
c) A list of workers formally authorized to carry out confined space activities must be available at the
site.
d) The competency of each worker who carry out confined space activities must be periodically
evaluated and documented.
d.1. Evaluation of competency must be conducted at the time of initial and refresher training.
e) Line management must ensure that on-going observation of workers skills and compliance is
carried out as part of daily operations and that the information gathered is used during
competency assessment.

7.1. Roles Relating to Confined Space Entry


The Country must include these roles in their procedures for confined space.

7.1.1. Confined Spaces Entry Permit Issuer


One person must be identified as being responsible for the confined space entry. This person is also
responsible for issuing any required Permit to Work.

The Confined Spaces Entry Permit Issuer (CEPI) must:

a) Be competent in confined spaces identification and assessment, associated controls, and of


hazard/risks associated with activities that are to be carried out within the confined space
b) Ensure that pre-entry requirements established in the entry procedure have been met before
entry is allowed.
c) The Permit Issuer is not permitted to enter the confined space.

7.1.2. Attendant
For confined spaces a person must remain outside and close by the confined space.

Attendant must:

a) Ensure that 2-way communication is maintained with those inside the confined space
b) Prevent unauthorized entry into the confined space.
c) Monitor the activity, and if he/she believes safety is compromised, order the evacuation of the
confined space.
d) When necessary summon emergency assistance.
e) Remain at all times aware of the number of people working within the confined space.
f) Not be doing any other task whilst acting as the Attendant.
g) Not enter into the confined space. In an emergency he/she must remain outside of the confined
space, but they may assist in rescue activities.

7.1.3. Entrant
The person(s) who enter the confined space must:

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a) Be authorized to enter the confined space.


b) Be competent in relation to the nature, hazards and risks of confined space working and of any
activities that they will carry out whilst inside the confined space.
c) Not enter into the confined spaces if the Attendant is not present and exit the confine space if
attendant has to leave
d) Understand the methods of maintaining communication, and of the emergency procedures.
e) Inform the Attendant of any risks encountered during entry, work or egress that were not
previously identified..

7.2. Training Delivery


Training requirements must be defined by the Country and, as a minimum be comprised of:

Who Where Initial Refresher

Confined Classroom - Theory 8 Hours 3 Years


Spaces Permit Controlled place - Practical (2 Hours)
Issuer

Attendant Classroom - Theory Duration of 8 hours Every 3 years


Controlled place - Practical (4 hours Classroom & 4 hours practical) (2 hours classroom +
1 hour practical)

Entrant Classroom - Theory Duration of 8 hours Every 3 years


(1) Controlled place - Practical (4 hours Classroom & 4 hours practical) (2 hours classroom +
1 hour practical)

Rescuer Classroom and practical 8 Hours 1 Year


(Anyone involved in CS rescue) (4 Hours)
When training requirements (training duration and refresher period) for the above mentioned roles are defined by country
regulation, country regulation will apply. When there is no country regulation applicable, the above table must be used.

a) Where a Permit Issuer, Attendant or Entrant has not carried out their role in the previous 12
months, they must undergo refresher training to maintain their personal authorization.
b) Refresher training must also be carried out when an incident investigation or audit identifies a
competency deficiency.
c) The following persons must be aware of and understand the requirements of this Standard as
they are defined within the Country’s own confined spaces Standard:
c.1. The person(s) responsible for conducting the confined spaces survey.
c.2. The person(s) responsible for providing technical expertise support on hazardous, flammable
and explosive atmospheres.
c.3. Maintenance Manager.

8. Record Retention
The requirement for record retention in this standard is an exemption from the Group HSMS
Standard.

a) Records relating to the inspection and maintenance of confined spaces and any related
equipment (e.g. gas detectors) must be retained in accordance with manufacturer’s requirements,
or for a minimum of 36 months, whichever is the longer.

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b) When, according to manufacturer, specific maintenance and inspection activities are to be


completed at a frequency that is longer than every 36 months, the last two specific inspections
/maintenance records must be retained.
c) Permit to work records must be retained for at least 6 months.
d) Records relating to the initial installation or the modification of confined spaces must be retained
for the duration that they remain in use plus 36 months.
e) Records relating to worker confined space competency and training must be retained for the
duration that they remain as employees plus 36 months.

9. Document Control
The latest version of this document, and therefore the only controlled version, is available on the
Group Intranet Health & Safety pages. No other copy of this document is to be considered to be the
latest or controlled copy.

https://intranet.lafargeholcim.com

Latest Version / Date Change since the previous version/revision

Version 1.0 / Feb 1, 2018 First publication.

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HSS-104

Appendix 1- Definitions
Term Definition
Asphyxiant An atmosphere that contains chemicals that are asphyxiant. An asphyxiant gas is a
atmosphere gas which reduces or displaces the normal oxygen concentration in breathing air.
Examples of asphyxiant gases are nitrogen, butane, carbon dioxide or propane.
Competent person Someone who has sufficient skills, knowledge and experience to complete the assigned
tasks properly. The level of competency required will depend on the complexity of the
situation and the particular tasks or responsibilities that they are assigned.
Confined space Any substantially enclosed space (although not always entirely) that is not designed for
continuous occupancy that has at least one of the following characteristics:
 Contains or has recently contained a (potentially):
o Oxygen enrichment or oxygen deficiency, or
o Toxic or asphyxiant atmosphere, or
o Substances that pose health hazards in case of inhalation, or
o Any other recognized serious safety or health hazard(s), or
 Contains a material with the potential for engulfment.
 Has an internal configuration where:
o Accumulation of a gas, vapour, mist, fume or ignitable dust with risk of fire or
explosion is probable, or
o Extreme Temperature is probable, or
o Walls converge or where a floor slopes downward and tapers to a smaller
cross section, or
o Makes quick escapes difficult or restricts entry for rescuers
Confined spaces can be classified as:
 Permanent Confined Spaces: where the space is always deemed to be confined
 Temporary Confined Spaces: where certain activities can change a safe enclosed
space into a confined space
Entry The action by which an Entrant enters a confined space. Entry is considered to occur
when a person’s breathing zone (i.e. 25-cm or 10-in radius surrounding the nose and
mouth) breaks the plane of the opening into the space.
Note: In circumstances where the contents or atmosphere of a space may present hazards to
workers positioned outside (i.e. presence of inert purge gases or hazardous substances), entry may
be considered to occur when a person’s breathing zone crosses an extended radius outside the
opening to the space, as determined by a risk assessment.
Formal A documented, time-limited authority to carry out specific tasks issued by another person
authorization that has the authority to give it. The duration (time limit) of formal authorization must be
no greater than the planned refresher intervals.
Oxygen deficiency Acceptable Oxygen levels are 19.5% - 22.5% by volume
/enrichment
Practicable Something is practicable when the time, effort and cost to do it is not grossly
disproportionate to the benefit that would be gained by doing it.
Procedure audit A process, carried out by competent persons, to systematically obtain evidence about
the level of implementation and effectiveness of a procedure. The objective of a
procedure audit is to ascertain whether or not: a) a specific procedure has been
implemented and is being complied with, and b) to assess the effectiveness of the
procedure under all operational conditions. The normal process is to examine the
documented procedure prior to the audit, and to design a set of tests that the auditor will
use to obtain the evidence necessary to enable the auditor to make a proper
assessment. Tests must include visual observation of the procedure in action, questions
and discussion with workers involved in the process, and inspection of records.
Toxic Atmosphere An atmosphere that contains chemicals that are toxic.
Note: The Threshold Limit Values (TLV) from the American Conference of Governmental Industrial
Hygienists (ACGIH) must be used. Concentrations of toxic contaminants must meet the 8 hour Time
Weighted Average Exposure Limit, a 15-minute Short-Term Exposure Limit, and the Ceiling
Exposure Limit for the contaminant tested before the atmosphere may be considered “acceptable”.

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