(SE Manual Caley Section) Policy: Confined Space Entry 1.0 PURPOSE, ul The purpose ofthis policy ist define the process to manage safety when person rel are required to enter a space meeting the definition of a confined spac. 20 SCoPE 24 22 ‘The scope of this policy is applicable to Hercules Offshore and all subsidiary and afiliate companies. During shipyard projects where shipyand personnel will be carrying out work on 8 Hercules Offshore asset, a bridging document wil be crested to address the Fed cml, State, and Local Regulations. 3.0. RESPONSIBILITY ev) 31 The Offhore Installation Manager / Person in Charge (OIMIPIC) | Facility Manager is responsible to ensure the confined space entty controls identified in this policy are integrated into the Permit to Work (PTW) and Job Safety Analysis (USA) processes to efctvely reduce the risks associated with confined space en- ty. ‘The Confined Space Designated Competent Person (DCP) shal: 3.2.1 Know the hazards that may be faced during entry, properly use equipment ‘or entry, and communicate wit ll persons involved, Know signs, symp- toms, and consequences of exposure. Understand emergency procedures. 332 Conduct ISA for intial entry for visual inspection. Conduct atmospheric test, perform interal visual inspection, and sign PTW in Confined Space Eny section 33.3 Ensure hazans ae controled / eliminated / mitigated before allowing oth- ers to enter, Ensure persons involved in task conduct the JSA./ PTW for the entry and those persons are competent to perform their duis. Verity a reseve plan is in place and all ivolved understand their emergency duties, 3.3.4 When work is complete, perform an interal visual inspection to confiem all persounel lave exited and equipment is cemoved ows the voufied Space and ensue thatthe confined space isnot reentered,THSE Mama (afey Section) Hercules Offshore, Ine. Policy: Confined Space try Revision: 3 Tasued: Apil2011 33, The Attendant shall 3.3.1 Properly use equipment fo monitor entty. Remain ouside the permit space during entry until relieved by another Attendant. Know the possible be- hivioral effects of hazard exposure to eniants. Communicate with en- tants. as necessary t monitor their status 3.32 Continuously maintain an secuate count of entrants inthe permit space. ‘Keep unauthorized personnel out of the confined space. Monitor activities inside and ouside the space for changes that could present « hazard ‘Summon the rescue team if necessary. Perform non-entry reseve if ap- proved by the DCP in the rescue plan. Perform no other duties while as- signed. 34 Entrants shal 3.4.1 Know the hazards that may be faced during entry, properly use equipment for entry, communicate with attendant, know signs symptoms of exposure and consequences, understand evacuation procedures. Participate in the JSA/PIW. 40° DEFINITIONS 4.1 Confined Space: A confined space is any space that isnot intended for human ‘ceupaney. Typically his includes any space designed to contain product such as liquids, bulk materials, gasses, or some other containment function that does not require routine entty by personnel. Eley and exit into confined spaces i limited ‘and usually consists of a small hatch that is bolted or dogged in place. Natural ventilation isnot or may not be adequate and fixed mechanical ventilation is not present. Some examples of confined spaces are preload, ballast, fuel, water, chemical or void tanks, spud cans, mat tanks, mud pits, cement / mud / gel bulk ios, and oppers 42. Oxygen Content (0): Breathing air contains approximately 20.8 % oxygen and thie value ean be rounded up to 219%. The only acceptable oxygen range for confined space entry i between 20% and 22%, An oxygen reading below 19.5% is considered oxygen deficient and dangerous. A reading above 22% is considered oxy yon enrete ad present ire Iza whic iy bo UanyeriTHRE Maneal Caley Soetion) Hereules Offshore, Ine. Poliey No. HSE 100.10 Revision 3 Policy: Confined Space Fry Athor:N. Maguire Ted! Apil2011 Approval R, MeClaine Page 3 of 9 43 44 50 PROCEDURI su (ev) 52 53 Lower Explosive Limit (LEL): The lover explosive limit value measures the concentration of explosive vapors with ar mixture expressed as percent (9). LEL ‘of 10% of more is considered a highly flammable atmosphere and is dangerous. ‘The only acceptable value of LEL for confined space entry or confined space hot work is zero (0%) 43.1 When performing hot workin a confined space, all adjacent spaces must be atmoxphercally tested, Hot work on bulkheads ean eause an explosion ‘when heat transfers through the steel the other side, (adjacent space) creat- ing an ignition source. LEL in adjacent tanks shall be zero (0%). 432. Performing hot work within a confined space requires completion of ‘he Hot Work portion ofthe PTW Form. Non-Entry Reseue: The only type of rescue thatthe attendant may cary out if approved in the reseue plan by the DCP. Non-Enry Rescue iscartied out without the resever entering the confined space by using mechanical means to extract the ‘etm frm the confined space. S (General) Entry into a confined space must never be considered 9 casual or routine event Confined space entry shall only be performed under the controls of PTW. When the DCP must enter the space or adjacent spaces to perform atmospheric testing and othe intial internal visual inspection prior to validating the PTW, all other controls (ie, reseve plan, attendant, et.) must be in place. When confined space entry is necessary, a task specific SA. must be performed. ‘The ISA shall identity the need to obtain a Hos ar Cold Work Permit, as applica- ‘ile, prior to confined space entry. This task can only be authorized by the Re- sponsible Person (OIM/PIC/Facility Manager) because ofthe likelihood for high severity incidents vo oveur during confined space entry, Before « Hot or Cold Work permit, as applicable, can be issued allowing entry imo confined space, the atmosphere must fist he tested with a portable gas de- ‘ctor. Only persons that have reeived training as a DCP ot Shipyard Competent Person is familiar with the testing process as well as the operation and calibration ‘of the portable gas detector, shall determine iFa confined space i safe for entryTHSE Mansal Gaiety Section) Hereules Offshore, ne. Revision: 3 Policy: Confined Space Entry Issued: Api 2011 Approval. MeClaine (REY) 60 (REY) s4 ss 56 37 38 59 (Only after the JSA has been performed and the confined space atmosphere has boon tested and doterminod to be safe for entry can the Responsible Person con sider issuing 2 Hor or Cold Work Permit, as applicable allowing entry and work Within «confined space. The atmospheric testing of the confined space shall be ‘documented inthe space provided on the bottom section of the PTW form, SAF- Each separate confined space entered requites a separate Hot or Cold Wark Per- nit, as applicable, allowing for entry into a single identified space. ITother con fined spaces must be entered, they require a separate specific atmospheric test and a separate Cold Work Perit. The only exception for multiple confined space entries under a single permits for inspection of empty salt-water pre-load tanks to verify watertight integrity or to install / remove Blind flanges located within preload tanks or other tasks associ- ‘ated with moving the vessel If this exemption is used, ll entry controls must be ‘implemented and stmospherc testing performed for each prelond tank entered. For this particular job all confined spaces may be listed ona single permit Ia space most be entered and there is any doubt wheter the space is confined or ‘ot, then it shal be considered a confined space. If electrical or mechenical equipment is located inside the confined space and it ‘has the potential to cause injury, the additional controls of Energy Isolation as per Policy HSE 100.09 shall also be implemented and documented on the work per- mit. Confined spaces shall be identified by placing signage or stenciling to inform / remind personnel of requirements. Example phrase "Confined Space - Permit Entry Only” placed noar the entrance a the space to serve asa warning. PROCEDURES (Designated Competent Person [DCP)) 61 Only persons who have recived formal taining and have been certificated a¢ 2 Shipyard Competent Person or DCP shall determine if confined space is safe for entry. They shal sign the confined space entry ection ofthe Het or Cold Work Permit, as applicable, verifying oxygen content is acceptable andthe lower ex- plosve mit and toxte levels are zero,HSE Manual Gafety Section) Heresies Otohor, Ine Polley No. HSE 100.10 Policy: Confined Space Entry Revision: 3 Anthor: N. Maguire [ssued:Apeil2011 Approval R. MeClane Page 5 of 8 62 Others may be trained onboard to monitor the portable gas detector for changes ‘once inside the confined space. but they may net cert the space as safe for en m, 63 The name or names of employees’ onboard serving as DCPS must be posted in Permit Control. Each installation / vessel / fit is required to have at east one person onboard to fll his ole tal imes. 70 PROCEDURES (Atmospheric Test Results) 7.1 When a confined space atmosphere is tested and acceptable results are not achieved, personnel shall not be allowed t enter the space. The solution isto pro- vide mechanical ventilation and replace the unacceptable ai inthe space by cireu- lating fresh ae ino the space 72. The time required w obtain 2 good test while ventilating depends upon the size and placement of confined space openings, size, shape and depth ofthe confined space, and number and types of mechanical ventilation systems use. 73. Ivis imporant to test the atmosphere at several levels, Arcas within the confined space to be entered shall be tested in ation to the area near the enirance, Proper planning of confined space entry work wil involve opening, testing, an, if nec essary, ventilation wll in advance ofthe ob. 74 The confined spaces that we must enter should not contain toxic substances. If they are detected, we have a problem that must be investigated and resolved be- fore entry is allowed. 80 PROCEDURES (Calibration and Function Checks of Portable Instruments) 8.1 Fach installation / vessel facility that performs confined space entry shall have at least one portable gas detector that is maintained and fully operational. Installa- tions / vessels / facilities where confined space work is more frequent sball main- {ain additional gas detectors to serve as back up and provide adequate coverage ‘when multiple confined space entry requires frequent testing or continuous moni- toring. 8.2. Gas detection instruments must be maintained and calibrated according to manu ‘actrer’s instructions to ensure they are accurate, fully operational fully charged, and ready for we by the DCP.THSE Manual Gafey Seton) Hereules Onshore, Ine. Policy No HSE 100.10 Policy: Confined Space Entry Revision: 3 thor: N.Magaire Tanwed" Apeil2011 Approval R, MeClaine Page 609 (ev) 8 90 83 Each installation / vessel / facility must maintain a calibration Jog to document calibeation results and maintenance ofthe portable gas detectors as per manufac- 4 Prior o each use, the portable gas detectors shall be functioned tested in good ai tw determine proper operation of Oxygen and LEL readings. 8.5 Prequeney of Atmospheric Testing: 5.1 The atmosphere of the confined space must be thoroughly tested and de- temnined safe by the DCP prior to signing the confined space section of the pet 85.2. slong as personnel are inside ofthe coafined space, a mandatory retest ofthe atmosphere shall be performed at least every three (3) hours, and ‘more frequently if determined necessary by the DCP to ensure conditions have not changed 85.3. Hot Work within» confined space requires continuous monitoring of the atmosphere as well as continuous foreed ventilation. 6 Ia.confned space atmosphere test indicates even small amounts of toxic gasses, \we must ventilate until we can achieve 2e0 (0 parts per million [PPM))- IC we can't achieve zero then we have a prablem with afauty reading or toxie product ‘geting into the space and investigation wil be required before entry i allowed. PROCEDURES (Minimum Mandatory Control Measures) 9.1 Portable lighting used in confined spaces shall be explosion-proof. 9.2 auipment to provide forced ventilation shall be explosion-proof and properly ‘grounded. 9.3 Determine if personnel should wea full-body harnesses while inside a confined space to assist with rescue incase of injury. 9.4 Perform a JSA confined space work plan and review / discuss the confined space Rescue Plan,THSE Manual Gafey Seton) Hercules Ofshore, Ine. Revision: 3 sued Api! 2011 Approval MeClaine 100 10 9s 96 9 os Policy: Confined Space Entry Bnsure the Reseue Kit/ Pod is readily available for use, equipment is maintsined, and the rescue team s familie with equipment operation Riskeassess and provide fall protection for employees climbing ladders into Spaces tanks greater than sx (6) fet deep. ‘An Emergency Observer / Hole Watchman shall be positioned outside the en- ‘tance ofeach confined space whenever personnel ae inside the space. The des- Jgnated Observer shall never enter the space and never leave the enirance unless properly relieved. The function ofthe Observer i to monitor personnel inside the Space and serve asa communication link capable of rasing an alarm. ‘A Confined Space Rescue Drill shall be conducted to exercise the rescue plan once every six months ata minimum. PROCEDURES (Physical Hazards) The DCP shal, in addition to performing the atmospheric testing of the confined space, perform an inspection to determine if physical hazards within the space are present. Men Ufjing physical hazards will allow for mandatory control measures to be implemented within the space. 10.1 High temperatures causing heat tess and dehydration. 102 Excessive noise 103 Lighting no deat 104 Notable to communicate adequately requiring radios. 105 Walking surfaces wot, slippery, or uneven. 10.6 Obstacles o each limitations requiring ladders or scfTod GENERAL ma In addition to the potential hazard of @ confined space atmosphere being toxic, flammable, oxygen deficient, or oxygen enriched, other hazards exist and must be ‘ontrolfed. These sks may inelude the following.Herel THSE Manual Safety Section) Ofshore, Ine Revision: 3 Issued: Api! 2011 Approval R. McClane 20 n3 4 22 3 124 Policy: Confined Space Entry 11.11 Poor lighting due to fixed lighting not being avalable in the space, 11.1.2 The design ofthe space may have sloping sides, regular shape, and mul tiple level creating fall o slip hazard. 11.13 Residual liquid / moisture on the confined space bottom causing a sip hazard 11.14 Framing and stiffeners within confined spaces creating trip / fall hazards, TILL Aceess gained though a small hatch with a havard sod ladder ercating fa 11.16 Large spaces may limit verbal communication and visual contaet with personnel inside the confined space 11.1.7 Poor ventitaton / ie flow may allow atmospheric conditions to change and deteriorate quickly, ‘Toxic Gas: Porable gas detectors typically have sensors to detect for ether Hy- drogen uti (HS), or Carbon Monoxide (CO), or both. The acceptable value of toxic gus for confined space entry is zero (0 PPM). Toxic means poisonous ‘nd although itis permissible to work around very, very stall amounts of these tote gasses for short periods of time, we are notable to accurately monitor and regulate exposure times and concentration, Oxygen (0:) content and LEL ate measured in percent (%) and toxic gas con taminans suck as HS oF CO are measured in PPM. Measuring and determining how much toxie gas we can be exposed to safely can get complicated. Keeping it simple isthe best safety and our confined spaces should not have toxie gases. RECORDS Designated Competent Person training record, on-site, curren. Gas detceton calibration logs, on-site, one year. PTW forms, Permit Control, six months List of Designated Competent Persons, Permit Control, curentTHSE Mana Safety Section) Hercules Ofihore, Tne. Policy: Confined Space try Revision 3 Issued Apei 2011 Approval R MeClaine 125 Records of atmospheric tess, on permit, six months. 126 Confined Space Rescue Dil, on cto years, REFERENCE 13.1 HSE 100.08, Perit Work FTW) 15.2 HSE 100.09, Energy Isolation (Lock-Out/Tag-Ou) 133 VERP 060, Training and Deils