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ENVIRONMENTAL

HEALTH AND SAFETY


HANDBOOK
Cal Dive Office Locations and
Telephone Numbers
United States
Emergency Numbers: 1-713-361-2600 or 1-800-856-2915
U.S. Hotline: 1-866-360-0508

Corporate Office
Cal Dive International Inc.
2500 City West Blvd.
Suite 2200
Houston, TX. 77042
Phone: 1-713-361-2600
Toll Free: 1-877-361-2600
Fax: 1-713-361-2690

Broussard Support Base


Cal Dive International, Inc.
1610 St. Etienne Rd
Broussard, LA 70518
Phone: 1-337-857-6178

Fourchon Marine Base


Cal Dive International, Inc.
536 Dudley Bernard Rd.
Golden Meadow, LA 70357
Phone: 1-337-587-5973 or 1-985-396-3839
Fax: 1-985-396-3961
E-Mail:fourchondock@caldive.com
Port of Iberia Support Base
Cal Dive International, Inc.
1902 Diver Drive
New Iberia, LA 70560
Phone: 1-337-374-0001
Toll Free: 1-800-856-2915

New Orleans
Cal Dive International, Inc.
1615 Poydras Street
Suite 1050
New Orleans, LA 70112
Phone: 1-504-522-4340
Fax: 1-504-522-3507

Lafayette
Cal Dive International, Inc.
322 Heymann Boulevard,
Suite B
Lafayette, LA 70503
P.O. Box 51294
Lafayette, LA 70505
Phone: 1-337-232-1275
Fax: 1-337-232-6574

Port Arthur Support Base


Cal Dive International, Inc.
8200 Yacht Club
Port Arthur, TX 77642
Phone: 1-409-962-6682
Toll Free: 1-877-962-6682
Fax: 1-409-984-1616

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Sabine Pass Support Base
Cal Dive International, Inc.
7366 S. 1st Avenue
Sabine Pass, TX 77655
Phone: 1-409-971-2633
Fax: 1-409-971-2158
Mailing address same as Port Arthur

Galvan Ranch
Mailing Address
109 Summerwind Blvd.
Laredo, TX 78041
Phone: 713-586-3960 or
956-419-2904

International Offices
Southeast Asia
Cal Dive International Pte, Ltd.
Main Corporate Office Singapore
Phone: +65-62543866

Cal Dive International Pte. Ltd. (Free Zone)


United Arab Emirates
Phone: +971 6 5262230

PT Cal Dive International Indonesia


Jakarta
Phone: (62-21) 252-3240

PT Cal Dive International Indonesia


Batam Island, Indonesia
Phone: (62-778) 705-7129
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Australia
Cal Dive International (Australia) Pty. Limited
Australia
Phone: 61-8-944-69988

East Coast Office Australia


Phone: 61-3- 5143- 3233

Mexico
Cal Dive International S. de R.I. de C.V.
Ciudad del Carmen, Mexico
Tel: 011 (52) 938-38-41037
Voice: 52-938-38-41037

Emergencies
In the event of natural disasters or other emergencies
effecting company operations, the return to work
information number is 1-866-360-0508.
In case of an emergency situation on shore in the US, dial
911 for assistance.
For ALL medical emergencies, injuries, incidents, material
releases, or evacuation situations, CDI Management must
be contacted immediately. A new list of personnel on call is
e-mailed each week to all assets and facilities. It is
necessary to contact only one person on the list, start with
the on-call EHS Manager. If the on-call EHS Manager is
not available, continue through the list until someone is
notified.
If unable to make contact with anyone on the list, contact
the CDI Dispatcher;

713-361-2600 or 1-800-856-2915.
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Table of Contents
Intr oduction ............................................................................. 9
Gener al Safety Rules ............................................................. 14
EHS Standar d #1: Per sonal Pr otective Equipment ................................................. 16
EHS Standar d #2 Fir e and Hot Wor k ...................................................................... 22
EHS Standar d #3 Lock Out/Tag Out (Ener gy Isolation) ........................................ 28
EHS Standar d #4 Blinding ........................................................................................ 34
EHS Standar d #5 Per mit Requir ed Confined Space Identification & Entr y......... 37
EHS Standar d #6 Hazar d Communication (HAZCOM) Right to Know ........... 45
EHS Standar d #7 Respir ator y Pr otection ................................................................ 50
EHS Standar d #8 Solid Waste Management ........................................................... 56
EHS Standar d #9 Natur ally Occur r ing Radioactive Mater ial (NORM) ................ 60
EHS Standar d #10 Wor king at Height (Climbing & Fall Pr otection) .................... 67
EHS Standar d #11 Hazar d Identification & Risk Assessment ............................... 71
EHS Standar d #12 Incident and Injur y Repor ting & Investigation....................... 79

Industr ial Hygiene Awar eness.............................................. 97


I. Hydr ocar bon Exposur e (Oil, Condensate, Gas) ............................................... 97
II. Bloodbor ne Pathogen Contr ol Plan ................................................................... 97
III. Hear ing Conser vation ........................................................................................ 97
IV. Hydr ogen Sulfide ................................................................................................ 97
V. Abr asive / Sandblasting Oper ations (Silica) ..................................................... 98
VI. Cor r osion Pr evention Chemicals ....................................................................... 98
VII.Nitr ogen............................................................................................................... 98
VIII. Paint ........................................................................................................ 98
IX. Radioactive Mater ials and Equipment (EHS-P-324) ........................................ 99
X. Heat Exposure .................................................................................................... 99

Gener al Safety ..................................................................... 100


I. Manual Lifting ................................................................................................ 100

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II. Chemical Safety ................................................................................................ 100
IV. Gas Cylinder Use, Stor age and Handling........................................................ 102
V. Cr ane Oper ations (EHS-P-328) ....................................................................... 102
VI. Cr ane Inspections ............................................................................................. 103
VII. Electr ical Safety .................................................................................... 105
VIII. Power Lines .................................................................................................... 106
IX. Fir e Pr otection ................................................................................................... 106
X. Fir e Pr evention Guidelines .............................................................................. 107
XI. Fir e Extinguisher Inspection and Maintenance .............................................. 108
XII. Welding and Bur ning (EHS-P-350) ..................................................... 108
XIII. For klift Oper ation ................................................................................ 109
XIV. Office Safety .......................................................................................... 110
XV. Shop and War ehouse ............................................................................ 112
XVI. Hoses and Air Guns .............................................................................. 112
XVII. Ladder s (EHS-P-327).................................................................................... 112
XVIII. Cleaning Agents (Refer to EHS Standar ds #1, #6 and #7) ..................... 113
XVIX. Hand Tools ................................................................................................... 113
XX. Power Tools ........................................................................................... 114
XXI. Wir e Wheel and Gr inder s .................................................................... 114
XXII. Knife and Cutting Safety ...................................................................... 114
XXIII. Repor ting for Duty ...................................................................................... 115
XXIV. Tr anspor tation ............................................................................................. 115
XXV. Vehicle Safety ................................................................................................ 116
XXVI. Helicopter Tr anspor tation .......................................................................... 117
XXVII. Water Tr anspor tation ................................................................................ 117
XXVIII. Tr ansfer by Per sonnel Basket .................................................................. 118
XXIX. Tr ansfer by Swing Rope .............................................................................. 118
XXX. Wor king Alone or in Isolation ...................................................................... 119

Repor ting ............................................................................. 120


I. Company Employee and Subcontr actor Injur ies ............................................. 120
III. Near Miss Incidents .......................................................................................... 120
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IV. Vehicle Collision ............................................................................................... 120
V. Pr oper ty Damage/Business Inter r uption Loss ................................................ 121
VI. Spills .................................................................................................................. 121

Conver sion Tables/Rigging/Char ts/For mulas .................. 122

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Intr oduction
Pr eface
To our fellow employees and subcontractor employees:

The CDI Safety and Environmental Handbook provides rules and guidance for safe work
practices and conduct. This handbook is based on regulatory requirements, CDI requirements,
industry best practices, field experience, lessons learned, and is an integral part of the
company injury, illness, and incident prevention process. Each employee and subcontractor
shall review, understand and use this handbook as a resource to control hazards associated
with their assigned tasks. Remember your co-workers, friends, and family are depending on
you to arrive home incident and injury free.

This handbook covers many, but by no means all, of the jobs and situations encountered in
our operations and in no way supersedes any established, controlled policy or procedure. It is
meant to supplement these documents in an abbreviated, easy reference format. When in
doubt, or when directed, please check with your supervisor/person-in-charge or reference the
associated CDI procedures, work instructions, or manuals.

On A Mission to Incident and Injury Free

It is our goal to safeguard employees health, eliminate injuries to people, control losses, and
to protect the environment. We believe that this is possible by recognizing and correcting
unsafe conditions and changing unsafe worker behaviors.

This handbook has been prepared with your personal safety and well-being in mind and is to
be used as a tool to assist each of us in incorporating safety into our daily activities. All are
expected to read the handbook carefully, adhere to its contents and use it as a ready reference
as daily work assignments are performed. We encourage all to share knowledge gained and
mentor others by leading by example and working safely.

Safest Regards, in the belief that, All Injuries Can and Should Be Prevented.

Senior Leader ship Team

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Our Vision:

PEOPLE GOING HOME SAF ELY

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Cor por ate Envir onmental, Health, & Safety Policy Statement
Cal Dive International embraces environmental, health, and safety objectives as core business
values.
The company shall endeavor to provide for employee livelihood, client needs and shareholder
returns through application of management systems that protect the environment, safeguard
employees health and eliminate injuries to people.
Cal Dive International believes these goals may be best achieved by:
Senior Management leadership and involvement
Education of employees on safe work performance
Proactive hazard identification, elimination, and control
Continual EHS improvement process
Promotion of an Incident and Injury Free Safety Culture both on and off the
job
Accepting that safety is good business and a critical aspect of a high
performance organization.
Cal Dives business plans include measurable EHS targets so that everyone who performs
work for the company is responsible to help achieve these targets.

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Envir onmental Health & Safety Roles & Responsibilities

Personnel as referred to in this handbook includes employees of the company and


subcontractors. Company employees, supervisors and subcontractors have the following
responsibilities:

MANAGERS/SUPERVISOR
Each manager/supervisor is responsible for health and safety of his employees and all
safety/environmental activities within their area of supervision. This will include
reinforcement of the belief that all injuries can be prevented. These responsibilities include:
To read, understand and comply with the company EHS policy statement,
EHS management system arrangements and controls.
Assuring accountability through employee performance reviews,
counseling and disciplinary action.
Setting a good example and promoting safety and environmental
initiatives.
Performing safety/environmental assessments and promptly correcting
substandard conditions.
Leading and documenting site orientations, safety/environmental
meetings, JSAs and risk assessments.
Reporting, tracking, and conducting investigations of injuries, incidents,
and giving appropriate feedback.
Reporting and investigating spills/releases.
Ensuring adequate training of employees for their assigned tasks.
EMPLOYEE
Each employee shall demonstrate a positive attitude toward injury prevention, the
protection of the environment and company property. Each employee shall accept that all
injuries can and should be prevented. Each employee is responsible for:
Stopping an activity or shutting down any operation which is unsafe
(including those of subcontractors).
Promptly reporting all incidents and injuries, unsafe conditions and
practices (including those of subcontractors) to their supervisor and
cooperating with investigations.
Reporting any injuries and illness that are non-work related that could
impact their ability to work

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Reporting every spill/release to their supervisor.
Performing their job safely, for their personal safety, the safety of fellow
workers, and the protection of the environment and company property.
This includes the proper use of safety equipment and strict adherence to
safe work practices and established Safety Standards.
Understanding all safety/environmental policies pertinent to their job
responsibilities.
Participating in site orientations, training classes, meetings, JSAs, and
risk assessments
SUBCONTRACTOR
As a condition of employment, subcontractors must take all necessary precautions for the
safety of all personnel at the work site. Subcontractors will comply with all company EHS
standards, as well as federal, state, and local safety/environmental laws, rules, and
regulations. Subcontractors will have in place an active injury and loss prevention program.
In addition, Subcontractors must:
Stop an activity or shut down any operation which is unsafe
Promptly report all unsafe conditions and practices to their supervisor and
Cal Dive on-site leadership, and cooperating with investigations.
Comply with Cal Dive EHS standards and practices.
Perform all work in a safe, environmentally sensitive, and professional
manner and provide required safety equipment for their employees.
Report all injuries, spills/releases and incidents, (including property
damage) immediately to the company Supervisor and Cal Dive on-site
leadership

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Gener al Safety Rules
1. Immediately report all injuries, illnesses, and/or incidents, no matter how
slight, to your supervisor.
2. Immediately report all fires and spills, no matter how small, to your
supervisor.
3. Immediately report any unsafe condition or practice to your supervisor. Any
unsafe or defective machine, tool, material, or equipment shall either be
identified as unsafe by tagging or locking the controls to render it inoperable
or it shall be physically removed from its place of operation.
4. Horseplay or fighting on company premises or any work site while
representing the company is prohibited.
5. The illegal use, possession, transportation, or sale of drugs, alcoholic
beverages, firearms, deadly weapons, or explosives while on company
premises or in a company vehicle is prohibited.
6. The use of prescription drugs must be reported in advance to the employees
supervisor.
7. Employees reporting for work must be fit for duty and not be under the
influence of illegal drugs or alcohol.
8. Horseplay or fighting on company premises or any work site while
representing the company is prohibited.
9. Smoking is permitted in designated areas only. Specific non-smoking areas
are: the galley, berthing spaces, main deck areas where work is being
conducted, dive-control areas, and within 25 feet of fueling stations and
flammable materials, and gases.
10. Never over-ride or defeat a safety device. If a safety device is over-ridden
and/or defeated, the appropriate supervisor shall be notified, the device tagged
and locked if possible, with the action properly documented.
11. No work may be started in any area or on any equipment without the
knowledge and consent of the person in charge. Do not operate equipment on
which you are not trained.
12. Under normal operations, all tools, operating machinery, and electrical
switchgear must have all safety guards, switches, and alarms in place and
functional. All block valves on pressure relief systems must be locked or
sealed open, unless locked and tagged out.
13. All exposed jewelry including finger rings, loose clothing, unsecured long
hair, and other loose accessories are not to be worn while working.
Wristwatches shall not be worn within arms reach of rotating, electric or
unguarded machinery.
14. When ascending or descending stairways, use the handrail and take only one
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step at a time in order to maintain three-point contact at all times. Running in
work areas, except for emergency purposes, is prohibited.
15. Use only proper tools and equipment maintained in good working condition.
Operation of tagged out equipment is prohibited.
16. Erect barricades around hazardous areas such as holes, loose or missing
decking, trenches, overhead work, open unattended vessels or hazardous
storage areas. Do not cross or enter a barricaded area, only the person in
charge may grant permission for entry into these areas.
17. Climbing, standing, or walking on hoses, cables, ropes, piping or valves is
discouraged. Approved scaffolding, temporary platforms, ladders, and
appropriate fall protection (Standard #10) is required if working at heights
greater than six feet.
18. Fire extinguishers, alarm boxes, fire doors, air packs, eyewash stations, first
aid kits and all other emergency and life safety equipment must be in good
condition, inspected regularly and kept clear of any obstructions.
19. Use proper lifting techniques (such as bending of knees), obtain assistance for
heavier or awkward loads and use mechanical lifting aids when available. Do
not twist while lifting, pulling or carrying a load.
20. Where there is a conflict of rules, the more stringent will apply.
21. Unauthorized work absence (leaving a work place without permission) is
prohibited.
22. The use of knives in the work place is prohibited with the exception of: divers
working in the water, standby divers fully dressed, supervisors on the deck,
medics in an emergency or rescue situation, and galley personnel preparing
food. All other knife use must be authorized in writing.
23. All passengers in company vehicles, including rental cars, must wear seat
belts. The driver is responsible to ensure that all passengers are wearing seat
belts prior to putting the vehicle in motion
24. The use of cell phones is prohibited on work sites while operating equipment
and/or machinery.
25. The use of cell phones with hands-free devices while driving shall be used
only when safe driving techniques can be followed in accordance with state
and local laws.

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EHS Standar d #1: Per sonal Pr otective Equipment
Pur pose
To provide personal protection equipment requirements for company employees,
subcontractors and visitors.
Definitions
Don/Doff: To put on or take off.
Employer Responsibility: The Company is responsible for conducting training,
identifying proper Personal Protective Equipment for
employees and certifying that Hazard Assessments
and training have been properly documented for its
employees.

Supervisor Responsibility: Supervisors are responsible for leading by example,


setting the right tone and culture at the work site: all
injuries can and should be prevented, assessing
worksites and determining if there are hazards that
require PPE, completing a JSA as part of the work
site assessment and advising employees as to what
PPE is required for a particular job.

Employee Responsibility: Employees are responsible for wearing, maintaining,


inspecting and discarding PPE according to company
requirements and manufacturer instructions.

Hazard Assessment: Walk-through survey of work areas to determine


what types of Personal Protective Equipment are
necessary in order to prevent injury from any
potential hazard sources.

Personal Protective Equipment: Equipment designed to protect injury to the eyes,


hands, feet, face, head and other parts of the body
from hazardous substances or conditions. Depending
on the type of work, some or all of such equipment
may be necessary.

PPE: Personal Protective Equipment.

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Understanding: Demonstrated knowledge of PPE specifications for
each job type and how to properly don, doff, adjust
and wear it; limitations of the PPE; and the proper
care, maintenance, useful life and disposal of the
PPE.

Pr ocedur e
I. Company Requir ements
A. All employees, visitors and third party subcontractors shall wear appropriate
PPE and clothing when on company property including transportation to and
from jobs. The minimum required PPE when working in areas other than
offices is Hard Hats, Safety Glasses and Steel-toed footwear. If a designated
walk path is clearly marked and identified as a safe zone, then no PPE is
required. No other exceptions should be allowed.
B. PPE, provided by either the company, the individual or the subcontractor must
meet standards established by recognized governmental and/or industry
groups.
C. At job mobilization and demobilization employees must be properly dressed
and be in possession of all required PPE including a personal flotation device.
Employees are responsible for the serviceably and sanitary condition of their
PPE.
D. Excessively worn or damaged PPE is not to be used and will be replaced by
the company with the exception of footwear.
E. The Site Supervisor is responsible for ensuring that a Hazard Assessment has
been conducted for his/her area of responsibility. The assessment must identify
the workplace evaluated, the date(s) of the assessment, the person making the
assessment and the required PPE. A JSA may suffice as a worksite hazard
assessment. Additional information on Workplace Hazard Assessment for PPE
can be found in the company EHS Manual.
F. When the work sites or work locations are subject to the requirements of two
safety management systems, procedures or standards, then the system,
procedure or standard which is more stringent, will be up held.
II. Head Pr otection
A. All personnel working on or around company field locations and ships, when
not in a vehicle or the living quarters/office, shall wear a Hard Hat. Hard Hats
must be non-metallic (non-conductive or dielectric) and meet ANSI Z89.1,
Class E and G requirements. Exceptions are tasks performed in machinery
spaces when risk assessments rule out hazards to the head.

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B. The company will provide head protection (hard hat) that conforms to current
ANSI Z89.1 (Class E & G) to its employees and visitors. Third party
subcontractors will be required to supply their own head protection to their
employees and visitors.
C. Metal hard hats, bump caps or novelty head protection will not be allowed.
D. Hard hats must be inspected frequently for cracks or other signs of damage
and never modified in any way.
E. Hard hats should be replaced after 5 years of service or when showing signs of
damage.
F. Any hardhat involved in an incident in which it was struck by an object shall
be taken out of service.
G. Hardhats must be kept clean and sanitized with soap and water only.
III. Hear ing Pr otection
A. All personnel working in an area where the noise levels are 85 dB or greater
shall wear hearing protection. If a person has to raise their voice in order to
talk to person at a distance of three feet or less, hearing protection must be
worn.
B. Types of hearing protection:
1. Muffs - fitting over the ears. Muffs must be kept clean and sanitized
with soap and water or equivalent before use and/or switching users.
2. Reusable earplug - designed for multiple uses, one user only, and must
be cleaned with soap and water or equivalent prior to each use.
3. Disposable earplug - discard after use.
C. Site management personnel will determine locations and equipment that
necessitate the need for hearing protection, ensure PPE is available and
enforce all aspects of the hearing protection policy that pertain to his/her areas.
D. Probable high-noise level areas should be reported to company Supervision for
surveying and, if necessary, warning signs posted. Sound level testing will be
repeated when a change to the work area is made that will affect sound levels.
Employees will be notified of the results.
E. Appropriate warning signs must be posted in high noise areas which are 85 dB
(decibels) or greater. Each site must have posted a copy of OSHA 1910.95.
F. Appropriate warning signs must be posted on all high noise portable
equipment which are 85 dB or greater.
G. Annual hearing conservation training will be given to employees who are
exposed to noise levels of 85 dB (8-hour time weight average) during a regular
work assignment. Training will include the affects of noise on hearing, how
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employees can protect their hearing and the types, use and sanitation of PPE.
H. Baseline and annual hearing tests will be provided for all company employees
working in the field and/or a yard/fabrication facility. Tests of each individual
will be compiled and reviewed for problem results and/or shifts and employees
will be informed of results. Records will be kept as required by law.
The company will provide hearing protection to its employees and visitors.
Subcontractors must supply their own hearing protection to their employees
and visitors.
IV. Footwear
A. All personnel working on or around company field locations must wear
current ANSI Z41 approved safety-toed shoes/boots.
B. Slip-on toe protectors may be acceptable for visitors.
V. Eye Pr otection
A. All personnel in field locations, when not in a vehicle or the living
quarters/office, shall wear current ANSI Z87.1 approved safety glasses.
B. Safety glasses do not replace other types of eye protection currently required
for performing specific job tasks. Other required types of eye protection
include splash goggles when working with chemicals and face shields when
grinding, chipping or striking.
C. The use of contact lenses while welding or working with or around chemicals
is prohibited.
D. Personnel who require corrective lenses must wear prescription safety glasses
or ANSI approved eyewear designed to be worn over corrective lenses. All
eyewear must have side impact protection.
VI. Hand Pr otection
A. All personnel working at company locations shall wear hand protection
appropriate for the potential hazards. Examples of appropriate hand protection
include, but are not limited to:
1. Leather or leather-palmed gloves when handling wire rope
2. Cloth gloves when handling pipe
3. Chemical-resistant gloves when handling acids or caustics
4. Rubber gloves approved for electrical work
5. Insulated or heat-resistant gloves when burn protection is needed
6. Hydrocarbon-resistant gloves when using hydrocarbon based solvents,
cleaning agents or chemical.
7. Cut-resistant gloves when using knives in the galley
8. Kevlar gloves and sleeve when grit blasting
9. At a minimum divers should wear a Kevlar puncture-resistant glove
during dives
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B. No gloves will be worn while working with rotating equipment.
C. Rings are prohibited while working.
VII. Respir ator y Pr otection (Refer to EHS Standar d #7)
A. All personnel working at company locations shall wear respiratory protection
where there is anticipated exposure to dust, residue from sand blasting, fogs,
fumes, gases and smoke.
B. The company will provide its employees with respiratory protection
equipment as needed. Visitors and subcontractors will provide their employees
with approved respiratory equipment as needed.
C. Personnel who are issued respiratory protection equipment must receive prior
training in the care, use, and limitations of the equipment. Records of training
will be maintained by the company training department.
D. Refer to the company Respiratory Protection Standard for proper identification
of required respirator for the work task.
VIII. Flotation Devices (PFD/Wor k Vest/Life J ackets)
A. All personnel who work over water must wear a fully secured work vest, of
the appropriate type, while performing their job duties, except when working
on immovable installations where handrails are provided.
B. All personnel must wear a work vest or life jacket when:
1. Boarding or disembarking vessels except at a dock equipped with an
enclosed gangway;
2. Traveling in a helicopter over water as provided by the operator;
3. Conducting ship abandonment drills, life jacket required;
4. Within 6 feet of unprotected opening or sides of any vessel;
5. Onshore at waters edge, in areas unprotected by handrails or outside the
handrails of a vessel;
6. Below the main deck of a platform or rig or as required.
IX. Fall Protection (Refer to EHS Standard #10)
A. A full-body safety harness with fall-arrest system must be worn any time
personnel are subjected to a fall potential of six (6) feet or more and which is
not otherwise protected.
B. The full body safety harness must be properly worn with the anchor point
equal to the height of the d-ring or higher and ensuring 100% tie off.
C. The company will provide its employees with a full-body safety harness and
fall arrest system when needed. Visitors and subcontractors will provide their
own approved fall protection system.
X. Tr aining

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A. Prior to working at a company work site, every company employee shall be
trained in the use of appropriate PPE and demonstrate an understanding of
the training.
B. Retraining shall be required when changes in the workplace render previous
training obsolete, changes in hazards have occurred or changes in the types of
PPE has rendered previous training obsolete.
XI. Responsibility
A. Site Supervisor
B. Individual employee

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EHS Standar d #2 Fir e and Hot Wor k
Pur pose
To establish proper safety precautions and controls to prevent fires and/or explosions while
conducting Fire and Hot Work operations. Fire and Hot Work that is conducted on client
premises will be conducted in accordance with the more stringent of the two Fire and Hot
Work permitting processes. Specific actions regarding Fire and Hot Work conducted
aboard ships and/or barges are contained within this standard.
Definitions
Classified Areas: Classified areas are defined as:
All offshore platform or rig areas except
those otherwise designated as approved
hot/safe work areas.
All shipboard areas except those areas
designated as smoking areas by the Ship
Master.
Areas within 35 feet of flammable or
oxidizing agent storage areas; this
includes, but is not limited to, fuel
tanks, fueling stations, paint lockers,
dive control vans, hyperbaric chambers,
oxygen or acetylene bottles.
Any other area as deemed necessary by
site supervision.
The Senior Site Supervisor/ Manager
must approve and document any
exception via the Management of
Change process.

F ire and Hot Work: Fire and Hot Work is defined as any open flame,
welding, burning, grinding, or any spark-producing
activity.

F ire Watch: The person(s) and associated fire protection


equipment assigned to stand by during permitted
welding, cutting or open flame conditions. The
responsibility of fire watch will be this individuals
only function.

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Designated Hot Work Areas: Designated Hot Work Areas shall be established for
the purpose of conducting welding or burning
operations on a daily basis.
Designated Hot work areas must be free
of combustible materials.
No hydrocarbons or other flammable
may be stored or used within 35 feet of
the Designated Hot work area.
The Designated Hot work area must be
equipped with a fully-charged and
inspected fire extinguisher.
All Designated Hot work areas must be
clearly marked and identified as an area
approved for Fire and Hot Work.

Lower Explosive Limit (LEL): The lower limit of flammability of a gas or vapor at
ordinary ambient temperatures expressed in percent
of the gas or vapor in air by volume. No Fire and Hot
Work will be allowed if the atmosphere is greater
than 10% of the LEL.

Site Supervisor: An employee designated as the site supervisor by


company management.

Pr ocedur e
I. Gener al Per mit Pr ocedur es
A permit is required in all company operations for any work affiliated with
operations requiring an open flame, welding, burning, grinding, blasting, opening
energized electrical junction boxes or portable spark producing devices including
heaters, electrical hand tools and/or portable equipment not rated intrinsically safe
within a classified area. No work covered by these guidelines may be begun before a
permit is issued. (Refer to Standard #13 Permit to Work).
A. Fill out the permit. All conditions of the permit must be met and the permit
must be signed.
B. Review the permit conditions. The company Site Supervisor must verify that
the following steps are completed before signing a Fire and Hot Work Permit.
1. All related equipment has been properly prepared and isolated as
23
outlined in the company Lock Out/Tag Out and Confined Space Entry
Guidelines. (Refer to EHS Standards #3 Lock Out/ Tag Out and #5
Permit Required Confined Space).
2. The permit has been reviewed by the Job Supervisor, the party
responsible for the job or consultant in charge of the facility or area.
The Site Super visor must physically r eview the ar ea and oper ating
conditions befor e signing the per mit.
3. Provisions must be made, if required, for the following:
a. Scaffolding. (Refer to EHS Standard #10 Working at Height).
b. Drains and sewers covered with proper vapor barrier.
c. Isolation of Fire and Hot Work area from other equipment or
areas using fireproof tarps or water fog.
d. Proper ventilation of equipment.
e. Trained personnel for fire watch equipped with the proper fire
extinguisher and safety equipment.
f. Emergency response.
g. Shoring and benching for excavation. (Refer to EHS Standard
#11 Hazard Identification & Risk Assessment).
4. A pre-job safety meeting and JSA or HIRA has been conducted to
ensure all safety and health precautions are understood by the person(s)
who will perform the work. Person(s) performing the work should sign
the permit.
5. Necessary gas tests have been performed for explosiveness, toxicity or
other hazardous conditions with readings recorded on the permit.
(Consult the company EHS Department for assistance if needed).
6. The welding/cutting equipment has been inspected for the following:
a. Cracks, splits or loose connections in welding leads. Repair
before use or Red Tag.
b. Exhaust spark arrester and drip pans on machines used offshore.
c. Leaks in connection to oxygen or acetylene bottles, hoses and
valves.
d. Installation of back flow valve/flash arrester.
7. Fire and Hot Work permits will be issued for:
a. A maximum of 12 hours of continuous work.
b. Until shift change

24
c. Until changes beyond those in the original permit.
8. Fire and Hot Work Permits will be issued for specific tasks only.
9. Approve the permit.
a. The company Supervisor, after verifying that all permit
requirements have been met, may sign the Fire and Hot Work
Permit.
II. Shipboar d Specific Pr ocedur es:
A. This section is directed towards Fire and Hot Work conducted on company
owned, leased or rented ships, boats or barges.
B. The Fire and Hot Work permit may only be issued by the
Master/Captain/Superintendent. In case of the
Master/Captain/Superintendents absence or at his direction, a designated
Mate, Chief Officer, Chief Engineer, Engineer, Port Captain or Port Engineer
can issue a permit.
C. The person requesting the permit must show the
Master/Captain/Superintendent exactly where he wants to conduct hot work in
order to receive a permit. No deviations will be allowed.
D. Hydrocarbons or flammables cannot be used or stored within 35 feet of the hot
work area unless protected by using fireproof tarps or water fog.
E. A fire watch must be present on the opposite side of the bulkhead from where
the Fire and Hot Work is being performed. A fire watch shall not be allowed in
any void, potable or ballast water tank unless entry is conducted according to
company Confined Space Entry Standard. (Refer to EHS Standard #5 Permit
Required Confined Space). Precaution should be taken to ensure the tank has
no combustible gases present. The fire watch shall have no other duties and
remain for 30 minutes after the burning or welding has ceased.
F. Any fuel tank vents within a 35-foot radius of the Fire and Hot Work must be
checked to ensure the presence of 30X30 mesh (flame) safety screen. If no
screen is in place, then vents must be closed, plugged or otherwise secured.
This activity must be documented on the permit to assure the proper removal
once the job has been completed. When the job is complete, any vents that
were secured must be immediately reopened. The Port Engineer or Technical
Manager must be notified if the flame safety screen is not present.
G. No Fire and Hot Work will be permitted directly on or adjacent to the skin of a
fuel, oil or sewage holding tank. Fire and Hot Work may only be conducted
after the tank is cleaned, purged and certified gas free by a Marine Chemist.
H. Fire and Safe Work will only be permitted in a confined space once a Shipyard
Competent Person/Marine Chemist has certified the space safe for hot-work.

25
I. Any person conducting Fire and Hot Work must have a designated fire watch
and an appropriate designated fire-extinguishing agent within 10' of the work
area.
J. Fuel transfer operations shall not be conducted simultaneously with an open
Fire and Hot Work permit.
K. Fire and Hot Work shall not be conducted at any marine-fueling terminal.
III. Oper ations under Per mit
A. All work shall meet all the requirements of the permit.
B. Immediately after the work is completed, the work area and adjacent areas will
be inspected to ensure there has been no spread of sparks or heat. The permit
will be returned to the supervisor after the job is complete and the area is
secure.
C. No Fire and Hot Work will be permitted in the presence of an explosive
atmosphere.
D. No Fire and Hot Work is permitted on any flammable substance storage tank,
barrel or container.
IV. Responsibilities under Per mit
A. All involved personnel shall be fully aware of and comply with all safety
regulations. Additional responsibilities are as follows.
1. The person taking out the permit shall:
a. Fully complete the Fire and Hot Work Permit Standard and
ensure that all requirements of the permit are met.
b. Coordinate the work with the company Supervisor or designated
alternate in charge.
c. Sign the permit.

2. The person doing the work shall:


a. Complete gas tests, if necessary, to determine explosiveness,
toxicity, or other hazardous conditions.
b. Inspect and place fire extinguishers, fresh air equipment and other
safety equipment.
c. Sign the permit.
d. Advise other personnel in the vicinity not to perform any
operation that is likely to change the conditions and thus void the
permit.
e. Prevent other operations that may conflict with the permitted

26
work.
f. Instruct all personnel concerned to stop work if a change occurs
that can create an unsafe condition.
g. Inspect the work area after the work is complete.
3. The company Site Supervisor or the designated alternate shall:
a. Ensure the safety of personnel and equipment under his/her
supervision.
b. Ensure that all elements of the permit procedure are completed.
c. Sign the permit.
4. The person doing the work shall understand the conditions of the Fire
and Hot Work Permit and sign the permit before starting the job.
5. The Fire Watch shall:
a. Not perform any other duty while watching.
b. Possess knowledge of and use of fire equipment as necessary.
c. Stop the Fire and Hot Work if sparks, flame or heat is projected
outside the permitted area.
d. Alert personnel entering the permitted area of hazards, i.e., arc-
flashes, grinding, cutting, overhead hazards, etc.
e. Must remain at site for a minimum of 30 minutes to assure non-
flare up from heat.
f. Sign the permit after the 30-minute safety period.
g. Tag, document and turn in any fire extinguishers that have been
discharged. Fire watch should use fire extinguishers designated
for fire watch only.
V. Tr aining
A. All affected employees will be trained in the
standard.
VI. Responsibility
A. Supervisor signing the permit.
B. Person conducting the work.
C. Person designated fire watch
VII. Exhibits
Fire and Safe Hot Permit (Refer to Standard #13 Permit to Work)

27
EHS Standar d #3 Lock Out/Tag Out (Ener gy Isolation)
Pur pose
Lockout/tagout standard is designed to prevent injury due to unexpected energizing
or start-up of machines or equipment, or the release of stored energy during servicing
and maintenance.
Definitions
Authorized Person: A person who places a lockout or tagout device on
equipment remove the lock or tag

Energized: Connected to an energy source or containing residual


or stored energy.

Energy Source: Any source of electrical, mechanical, hydraulic,


pneumatic, chemical, thermal, stored or other
potential energy.

Lockout: A device that utilizes a positive means such as a


lock, to hold an energy isolating device ensuring that
the energy isolating device and the equipment being
controlled cannot be operated until the lockout
device is removed.

Tagout: The placement of a tagout device on an energy


isolating device to indicate the energy isolating
device and the equipment being controlled may not
be operated until the tagout device is removed.
Pr ocedur e
These guidelines shall be followed prior to beginning dive operations from a vessel and
when performing repair and/or maintenance on all equipment including electrically-driven
machinery and equipment; mechanical equipment such as gas compressors, fire pumps or
cranes; hydraulic equipment; equipment operated by pneumatic, thermal or chemical
energy sources; and pressurized equipment.
I. Lock Out / Tag Out Per mit (Ener gy Isolation)
A. The supervisor and the person/persons performing the task must fill out the
permit.

28
B. All requirements of the permit must be met prior to the start of work.
C. The permit is valid for 12 hours or end of shift whichever occurs first.
D. Any unscheduled work stoppage, unforeseen hazard or emergency condition
nullifies the permit.
E. The completed permit will be turned in with the job paper work or maintained
with the project/worksite file.
II. Locks and Tags
B. All locks, tags, and other hardware required by this
guideline will
Be provided by the company.
Be available to all personnel at all times.
Have only one key for a lock or a set of locks.
C. Each tag
Shall note the equipment name/identification.
Shall note the condition or reason for tagging.
Shall note the date/time.
Shall include the signature of person applying the tag.
Each tag shall indicate the condition to be avoided by the lockout/tag
out, i.e., Do Not Start, Do Not Open, Do Not Close, Do Not Energize,
Do Not Operate, etc.
ONLY the person who placed the lock and tag in service can remove the
lock and tag.
Tags WILL NOT be used for any purpose other than lockout/tagout.

D. The following is an inventory list of the minimum lockout/tagout kit to be


maintained on each vessel or barge, onshore site and project.
Six(6) pad locks with a different single key per lock
Two (2) multiple lockout hasps
A log listing what item is locked out, who is locking it, time of lockout
and time of removal
Three wire lockout straps or chain for locking out valves and other
items
Twenty-five (25) lockout tags; Cardstock

29
Four (4) lockout tags; Vinyl
Twenty-five (25) nylon cable ties
Two (2) markers for tag identification
Two (2) black pens for filling out log of use
*Vessels or sites requiring additional lockout devices can order those items
separately
III. Gener al Lock and Tag (Ener gy Isolation) Pr epar ation and Installation
LOCK TAG-CLEAR-TRY
A. Survey the work area and equipment to verify that all equipment can be
locked out or secured. If an energy-isolating device is capable of being locked
out, then this standard requires that a lockout and tagout be utilized. Only
when an energy-isolating device is not capable of being locked out, shall a
tagout be utilized.
B. Shut down or turn off the machine or equipment to be worked on.
C. Physically locate all valves and switches and close, turn off or blind to
isolating any energy source from the machine or equipment to be worked on;
reviewing the most current flow diagram of the equipment will assist in
locating all isolation valves. (Remember some devices may have more that
one power supply.)
D. Render safe any stored hazardous energy by relieving, disconnecting or
restraining it.
E. Place a lock and tag on each energy-isolating device. The locking party
(authorized person) will hold the one key until completion of the job, or
authorized relief personnel complete the job.
F. Verify that the equipment is not operable.
G. Personnel
Only trained personnel are allowed to start up machinery or equipment.
When shift or personnel changes occur during maintenance, dive ops
and/or repair activities, the designated company representative in charge
shall ensure continuity of the lockout/tagout protection. Each worker
shall be responsible for removing his own padlock and tag at the
completion of his/her shift. If work is to cease until the following day,
the supervisor shall place his padlock and tag on the equipment and the
workers shall remove their padlocks and tags. When work resumes, the
worker shall affix his personal padlock and tag to the equipment and the
supervisor shall remove their lock and tag.

30
IV. Electr ical Lockout / Tagout (Ener gy Isolation) Pr ocedur es
A. The following procedures for lockout/tagout (Energy Isolation) (lock, tag,
clear, try) shall be followed when exposed to electrical hazards:
Perform an initial evaluation to determine exposure(s).
Notify affected personnel and properly shutdown/de-energize the
equipment.
The person doing the work shall lockout using an approved lock
(remember to LOCK open circuit breaker(s)). If the device cannot be
locked out, it must, at a minimum, be de-energized and tagged.
TAG the lock with a DANGER, DO NOT OPERATE tag.
Each person doing the work shall install a lock or tag. There must be
only one key for each lock and that one key shall be held by the locking
employee(s) until completion. A crew or group lockout is acceptable
only when the each member of the group signs the log that the
equipment is isolated. The employer may designate a "primary
authorized employee," who is assigned the responsibility for
implementation and coordination of LOTO, to perform this verification
step. The primary authorized employee must verify that the machine or
equipment is isolated effectively from hazardous energy sources before
authorized employees participating in the group LOTO affix their
personal locks/tags or sign a master tag and before performing
servicing or maintenance. In addition, after affixing a lock/tag or
signing a master tag and before performing servicing and maintenance,
each authorized employee participating in the group LOTO must be
allowed to verify that hazardous energy sources have been isolated.
The primary authorized employee must properly secure the key(s) of
the lock(s).
CLEAR the area of personnel and tools prior to trying to start the
equipment.
Before starting work, TRY to energize the equipment locally.
When work is complete, all affected personnel shall be notified, locks
and tags removed or the master tag signed and the equipment may be
placed back in service.
Only the person(s) originally attaching the lock and tag is authorized to
remove the lock and tag. If absolutely unavailable, the supervisor shall
initiate a Management of Change (MoC) for removal of the lock and tag
and notification of all parties.
Unplugging an electrical device does not constitute a lockout. The
device must be tagged and if possible a lock box placed over the plug to
eliminate the potential for plugging it into a power source.
31
V. Pr ocess, Hydr aulic and Pneumatic Ener gy Sour ces Lockout/Tagout (Ener gy
Isolation) Pr ocedur es:
A. At least one of the following lockout/tagout procedures shall be used to safely
isolate other types of stored energy sources:
Blinding of process piping, vessels and equipment in accordance with
Standard #4 Blinding.
Disconnection of piping.
Double block and bleed process piping where block valves are closed,
locked (chained) and tagged with a bleed or vent valve open in
between.
Single block valves closed, locked and tagged as minimum for certain
routine maintenance operations.
VI. Mechanical Ener gy Lockout/Tagout (Ener gy Isolation) Pr ocedur es
A. Chains, blocking, locking pins or other hardware shall be used for isolating,
securing or blocking of machines or equipment from mechanical energy
sources as required by the procedure and permit.
VII. Lock and Tag Removal Tempor ar y or Per manent
A. Reinstall all guards.
B. Return all exposed electrical wiring to conformity with electrical code
requirements.
C. Remove all blind flanges and properly connect piping.
D. Remove tools, materials and other nonessential items.
E. Inspect and verify that all machine or equipment components are operationally
intact.
F. Notify all personnel in the area that lockout/tagout (Energy Isolation) devices
are ready to be removed.
G. Ensure that all personnel are safely positioned or removed from the area.
H. Remove each lock and tag device from each energy-isolating device.
VIII. Lockout/Tagout (Ener gy Isolation) Log
A. A lockout/tagout (Energy Isolation) log will be maintained for each vessel or
worksite as applicable.
IX. Long Ter m Ener gy Isolation
Long term energy isolation is any planned isolation scenario that would exceed the standard
twelve (12) hour or end-of-shift parameters. Long Term Isolation or Lock Out/Tag Out or
equipment or devices must be approved by Management of Change. See EHS-P-348 MoC.
32
X. Lockout/Tagout (Ener gy Isolation) for Dive Ops
(This section does not address diving from DP vessels. Each DP vessel must
maintain and follow their specific diving permit system.)
A. On vessels it is the responsibility of the diving supervisor to inform the
Captain of any diving operation and obtain a permit to dive prior to beginning
diving operations. It is also the Captains responsibility to check with the
diving supervisor and dive station before starting engines.
B. All main engines will be isolated at the air starters or control and rudders will
be isolated or tagged.
C. All engine controls will be tagged out; Stop signs must be placed on the
engine starters and both throttles (in wheelhouse and stern control) to prevent
energizing of the wheels.
D. The person placing the stop signs must fill in necessary information on the
permit to dive. Only that person should remove the stop signs and sign the
log again.
XI. Employee Tr aining
The company shall provide training to ensure that the purpose and function of the
lockout/tagout (Energy Isolation) procedures are understood. Knowledge and skills
required for the safe application, usage and removal of lockout/tagout (Energy
Isolation) devices are training objectives.
XII. Responsibility
A. Site Supervisor
B. Master/Captain/Superintendent
C. Authorized Person
XIII. Exhibits (Located in the company EHS Management System)
Lock Out / Tag Out (Energy Isolation) Permit (EHS-F-317).

33
EHS Standar d #4 Blinding
Pur pose
To prevent the release of combustible and toxic liquids, vapors and gases into the work area
during maintenance, repair and construction of piping. To isolate tanks, vessels and spaces
scheduled for entry as outlined in EHS-P316 and Standard #5 Permit Required Confined
Space.
Definitions
Blind (slip blind): A properly sized and rated metal plate inserted
between pipe flange gaskets to prevent gas or liquid
flow in either direction.

Blind F lange: A full-rated pipefitting used to close the flanged end


of an open pipe or valve.

Blind List: A document identifying blind size, pressure rating,


location, date of installation and removal of blinds.
Also includes the name of person(s) installing blinds.
Any method used to prevent releasing combustible
liquids, vapors or gases into the work environment.

Spectacle Blind: A combination blind and spacer formed from the


same piece of material. Frequently a permanent part
of the line, this item may be taken out and the other
end inserted depending on whether or not flow is
desired through that line.

Pr ocedur e
I. Oper ations Onshor e and Above Water (Top Side)
A. Install blinds in all vessels, piping or equipment scheduled for hot work, entry,
repair or construction or demolition.
II. Pr ior to Opening Any Flange J oint to Install a Blind
A. Determine the exact location where blinds are necessary. Blinds must be
installed at the flange closest to the vessel or equipment, and on the side of
block valves most consistent with pressure testing requirements.
B. Ensure that equipment is properly prepared for blinding. Lines and equipment
should be depressurized and drained; the drain valves should be left open.

34
C. Identify the material contained in the equipment; if the material is hazardous,
wear appropriate PPE. (Refer to EHS-P-307, EHS Standard #1 PPE and EHS-
P-326, #6 Hazard Communication)

III. A Full-Rated Blind Should Be Installed With Thr ee Consider ations


A. The blind is properly rated for the service: Consult ANSI blind rating charts
for correct rating.
B. Blind is accessible and will effectively isolate.
C. The blind matches the line size.
IV. Installing Blinds
A. If gases are suspected to be at toxic levels, wear a self-contained breathing
apparatus or a clean air delivery system. (Refer to Standard #7 Respiratory
Protection)
B. Remove all flange bolts except two opposing bolts. Loosen these bolts without
removing the nuts and vent the flange away from you.
C. If wedges need to be hammered in, hammer and wedge must be made of a
non-sparking material such as brass or beryllium.
D. Install at least one gasket on the pressure side of the blind.
E. Install the blind.
F. Tag the blind using the Lockout/Tagout (Energy Isolation) procedure. (Refer
to EHS Standard #3 Lock Out /Tag Out).
G. A blind list log shall be prepared when a number of blinds are utilized to
ensure proper installation and removal. The blind list log shall include the
blind number, location and date installed, date removed and appropriate
signatures.
V. Oper ations Sub-Sur face (Diving)
A. Installation and removal of sub-surface blinds
Before attempting to install or remove a blind flange, check all available
sources to determine that the installation point where the blind is to be
installed is pressure neutral.
Consider use of a pollution dome if a spill hazard exists.
When attempting to remove a blind:
Locate the valve; position yourself away from the direct line of fire
should the valve fail. Operate the valve to determine if any pressure is
released or if suction exists. A diffuser or other safety device should be
installed.
35
If a valve is not present, look for a plug. Again, take a position to the
side of the plug. Remove the plug and look for the release of pressure or
the existence of suction. Always consider there may be a Delta P hazard.
a. If no valves or plugs are present, a Management of Change shall
be initiated before attempting to remove the blind. Stand to the
side of the flange and remove the nuts with a pattern that allows
the diver to maintain control of the flange until it can be
determined that there is no pressure behind the flange.

b. When the flange is removed, make certain that no petrochemical


product is leaking from the line. If product is being discharged
from the line, leave the area immediately. Do not attempt to stop
the discharge until the divers have been properly dressed to
protect themselves.
When attempting to install a blind:
a. Ensure that you have the correct size blind and properly rated
blind.
b. When approaching the pipeline or assembly, listen for a vacuum
sound.
c. Approach the assembly using a broom or mop to determine if
suction does exist.
VI. Tr aining
A. Shall be conducted for, but not limited to, project managers, dive supervisors,
divers and vessel personnel.
B. When approaching the pipeline or assembly, always consider that a Delta
Pressure Hazard may exist, listen for a vacuum sound. (Note, Do not rely on
sound, there may be no sound discernable.)
C. Approach the assembly using a tell tail such as a broom or mop to determine if
suction does exist.
VII. Responsibility
A. Line Supervisor
B. Project Manager

VIII. Refer ence


EHS-P-345 Blinding Procedure

36
EHS Standar d #5 Per mit Requir ed Confined Space Identification & Entr y
Pur pose
To establish procedures necessary for the safe preparation, entry and restoration of a
permit- required confined space to be entered by personnel. No work may be done in a
permit-required confined space until a permit has been issued for the work. This standard
does not apply to underwater diving operations and excludes saturation systems and
decompression chambers. This procedure is designed to permit man-entry and does not
authorize specific work. On vessels, a Marine Chemist or a Shipyard Competent Person
(specific training required) must authorize hot work in a confined space.

See EHS-P-316 Permit Required Confined Space Identification and Entry Procedure for
more details.

Definitions
Permit-Required Confined
Space (Permit Space): A confined space large enough in which a person
may enter but, has limited entry or exit and is not
designed for continuous employee occupancy, and
Has any one of the following characteristics:
1) Contains or could contain a hazardous
atmosphere;
2) Contains a material that could engulf a person;
3) Has an internal configuration which could trap a
person inside;
4) Contains any other recognized significant safety
or health hazard.
A permit space includes, but is not limited to: storage
tanks, tank trucks, process vessels, furnace boxes,
sewer systems, ducts, flues, manholes, valve boxes,
cellars, pipelines, pits or excavations, with side walls
four (4) feet or deeper, without easy means to enter
or exit or any other confined spaces which may
contain toxic or corrosive conditions, flammable,
oxygen deficient or oxygen rich atmospheres.
On a vessel, all tanks, vessels, voids, coffer dams,
areas accessible through a manway or similar
compartments will be considered a confined space.

Entry: The action by which a person passes through an

37
opening into a permit space. Entry includes work
activities in that space and is considered to have
occurred as soon as any part of the entrants body
breaks the plane of an opening into the space.

Company Site Entry Supervisor: The Company Site Entry Supervisor must be a
qualified competent person and is responsible for
proper identification and preparation of the permit
space to be entered. He/She should know the proper
procedure for testing and monitoring of the permit
space to determine if acceptable or prohibitive
conditions exist. In preparation for entry, a Confined
Space Entry Permit, (Refer to Standard #13 Permit to
Work) must be initiated and completed according to
the following procedures.

Entrants (Authorized Workers): One or more properly equipped and trained person(s)
who have been authorized by the company Site Entry
Supervisor to enter a permitted space. These workers
will be made aware of any known hazards, be
properly trained in the use of Personal Protective
Equipment required for entry and be versed in visual
and/or hand communication signals to enhance the
monitoring of the entrants status by attendant while
within the permit space.

(Attendant) Stand-by Personnel: One or more properly equipped and trained (First
Aid/C.P.R.) person(s) stationed OUTSIDE the
permitted space. The attendant shall protect the
entrants by continuously monitoring all activities
within and outside the permit space. At no time may
the attendant enter the permit space. If an emergency
situation arises, the attendant shall actively
participate in a non-entry rescue by requesting
emergency services, providing accurate information
to rescue personnel (number of entrants, possible
problems, atmospheric conditions, time of last
contact, etc.) and also assist in directing the
emergency situation. These shall be his only job
duties while posted as a standby.
Rescue Service: One or more properly equipped and trained person(s)

38
designated by the company Site Entry Supervisor to
rescue or remove injured entrants from permitted
spaces. This service should be stationed on site and
may be a designated employee or outside
subcontractor who is trained in this procedure.

Emergency Evacuation
Equipment: That equipment that is located outside the permit
space that would be needed to rescue or extract a
worker from the permitted space. The equipment is
not limited to, but should include the following: Self-
contained breathing apparatus or approved hose line
with escape feature, lifelines, harness and other
equipment such as hoist where rescuing workers
from deep excavations (five (5) feet or more in
depth) and/or large vessels would be difficult. A first
aid kit shall also be located at the work site.

Hazardous Atmosphere: An atmosphere containing flammable vapors,


oxygen deficiency or oxygen enrichment or any air
containment measured by instrumentation to be in
excess of allowable limits.

Isolation: Action taken to prevent the entry of hazardous


materials or the creation of hazardous conditions in a
permitted confined space.

Immediately Dangerous
To Life or Health (IDLH): A condition that poses an immediate or delayed
threat to life, could result in irreversible adverse
health effects or could interfere with an individuals
ability to escape unaided from the confined space.
Examples could include, but are not necessarily
limited to, oxygen deficiency, explosive or
flammable atmospheres and/or concentrations of
toxic substances (i.e., carbon monoxide,
hydrocarbons, hydrogen sulfide, etc.)

39
Procedure
I. Befor e Beginning Wor k
B. Permit space preparation:
The permit space must be properly isolated prior to entry. Isolation
shall incorporate the Lockout/Tagout of pressurized vessels/piping,
electrical sources, stored energy, and valves and hydraulic equipment.
(Refer to EHS-P-317 and Standard #3 Lock Out /Tag Out).
The installation of blinds is required where these lines may reasonably
cause contaminates to flow into the space. Disconnection and blinding
should take place as close as possible to the permit space. Any isolation
or removal of equipment should be documented on a blinding work
sheet and attached to the permit. (Refer to EHS-P-345 and Standard #4
Blinding).
The required duties of all employees/subcontractors will be reviewed
prior to opening the permit space. This shall include, but is not limited
to, the Site Entry Supervisor, authorized workers, standby personnel and
rescue services.
Upon opening the permit space, a DO NOT ENTER sign shall be
posted at the entrance. This sign shall stay in place until the Confined
Space Permit is completed and signed. A DANGER CONFINED
SPACE ENTRY IN PROGRESS, NO UNAUTHORIZED
ENTRANTS sign will be in place upon entering the permit space by
any occupant.
II. Atmospher e Checks and Pr epar ation
C. If natural ventilation is inadequate, mechanical ventilation must be
established to ensure movement of fresh air in the permit space. Mechanical
ventilation should be started prior to and after testing. Ventilation shall be
continued during the entry process to help reduce and/or eliminate
atmospheric hazards. The desired method of ventilation is to push fresh air
into the permit space.
On Vessels
Potential hazards presented by piping which run through void spaces
should be considered. (Refer to EHS-P-345 and Standard #4 Blinding).
The Marine Technical Manager / General Superintendent must approve
any exceptions to ventilation via the Management of Change process.
(Refer to EHS-P-348 and Standard #14 MOC)
If the atmosphere needs to be pulled from a permit space to ensure
proper ventilation, an air- driven or explosion-proof electric fans shall
be used. Internal combustion (non-explosive proof power sources) may

40
be utilized for forced air ventilation of the permit space when the work
site has all potential hazards secured and the air intake of the ventilation
system is placed in an area that prevents contaminants from entering the
fan intake and being discharged into the permit space.
Another method for air exchange is to fill the tank with seawater and
drain where applicable.
D. Atmospheric checks shall be taken at various levels of the permit space and
recorded on the permit. Ventilation shall be discontinued during this process.
In some cases, it may be necessary to enter the permit space to check properly
the atmospheric conditions. If this is required, an air-supplied respirator with
an approved facemask or self-contained breathing apparatus or an approved
hose line unit with an escape pack must be worn. In this case, the worker must
be attached to a lifeline or other rescue device during this initial entry.
E. The atmosphere within a permit space shall be
tested:
Prior to entry
After each break or interruption of work
At each shift change.
At intervals determined by the competent person and/or Marine Chemist
Following an employee complaint or concern
F. Test instruments shall be calibrated in accordance with manufactures
instructions. Each instrument shall be tested prior to its use for the completion
of a Confined Space Permit.
G. Atmospheric checks shall include the following:
Safe for entry Oxygen
a. Minimum 19.5%
b. Maximum 22 %
c. Oxygen levels must be checked before explosive levels
Safe for entry Flammable or Explosive Vapors (% of LEL)
a. 0% of LEL without respiratory equipment;
b. Maximum 10% of LEL with respiratory equipment
c. Above 10% of LEL, rescue purpose only with respiratory
equipment
Safe for Hot Work:
For Confined Space Hot Work 0% LEL

41
NOTE: The Environmental Health & Safety Department and
Marine Technical Manager / General Superintendent on vessels
or Facility Manager for Inland Operations shall approve any
exception via the Management of Change process. (Refer to
EHS-P-348 and Standard #14 MOC)
Safe for Entry Temperature
Maximum air temperature 125oF for allowable entry, Maximum wall
temperature 140oF
III. Site Pr epar ation
A. A safe means of access and egress shall be provided at all times when the
permit space is entered/exited from above or below grade. This could include a
portable ladder or scaffolding that is properly installed and secured for
climbing.
B. When entrance covers are removed, the opening shall be promptly guarded by
a railing, temporary cover, or other temporary barrier that will prevent an
accidental fall through the opening and that will protect each employee
working in the space from foreign objects entering the space.
C. All lighting equipment that is required for working within the permit space
shall be explosion-proof and have a ground fault circuit interrupter (GCFI).
Only intrinsically safe or explosion-proof flashlights are permitted for use
within the permit space when work will be limited to a short time period.
D. All electrical equipment (such as air movers and vacuum truck hoses) shall be
properly grounded or bonded to prevent static discharge (sparks).
E. Fire extinguisher(s) and other firefighting equipment shall be available at the
work site if flammable or combustible materials are present. The extinguisher
shall be inspected to confirm that it is in good working order.
F. Emergency evacuation equipment shall be available at the work site. The
rescue and extraction equipment will be inspected to ensure that it is in proper
working condition.
IV. Per mit Issuance
Upon completion of the above requirements, the entry supervisor shall review the
preparations and the permit space. If all requirements are met, the supervisor may
sign the permit, (EHS-F-316), have the permit initialed by the Person in Charge of
the vessel or facility, and shall post it conspicuously at the work site.

V. Entr y into the Per mit Space


A. Prior to entry, the entry supervisor shall review the following with all
authorized workers (employee/subcontractor): known hazards within the
permit space, the responsibility of each authorized worker (supervisor,

42
workers, stand-by personnel and rescue services) and the location and
procedures for calling for outside emergency services. Upon completion
of all confined space requirements, the Port Engineer / Technical
Manager on shore, EHS person on call, or the Facilities Manager for
land-base operations must be made aware that a confined space has been
deemed safe for entry and will proceed.
B. Authorized employees may enter the permit space only after all
Confined Space Entry Permit requirements have been met, and the
permit is signed and issued and management has approved the entry.
C. Unauthorized personnel shall not be allowed entry.
D. If the permit space is left unattended, the entrance shall be locked or
secured.
E. There will be a minimum of one Confined Space Attendant on duty at
the entrance to each space entered. The attendant shall have no other
duties that would distract from the monitoring of the entrants or the
space.
F. The permit space atmosphere shall be RECHECKED as often as
necessary while entrants are in the permit space to ensure a safe work
environment.
G. If conditions require a Hot Work Permit it shall be issued in accordance
with Fire and Hot Work Standard. (Refer to EHS-P-315 and Standard #2
Fire and Hot Work).
H. Stand-by personnel must remain in contact (visual, hand signals, soft
line, voice, etc.) with the personnel in the confined space at all times.
I. Authorized employees shall wear a full body retrieval harness with
attached retrieval line while working within the permit space. In spaces
that require a vertical descent of five (5) feet or greater, the retrieval line
shall be connected to a hoist.
J. Rescue services shall be on location while a Permit Space Entry is in
progress.
K. The Company offshore, competent person shall terminate the permit and
instruct all entrants to evacuate the permit space if:
An unauthorized worker enters the permit space.
Operations covered by the permit have been completed.
Conditions not allowed under the permit arise in or near
the permit space.
VI. Restor ation of the Per mit Space
When all work is completed, the permit space must be restored to normal service

43
conditions. Use the permit as a checklist for proper restoration. The entry supervisor
will review the work, the restoration of the permit space, and if everything is
acceptable, sign the permit and have the permit initialed by the PIC of the vessel or
facility. A copy of the permit should be kept with other records pertaining to the
work done. The original permit must be maintained on the vessel or at the site for six
months.
VII. Tr aining
Annual training shall be conducted to ensure that each employee is well versed as to
his/her role as an active participant in the entry of a permitted space. Instructions and
training material will be made available through the company Training Department
or an approved subcontractor.
VIII. Pr ogr am Review
Permit-required confined space entry permits must be reviewed periodically, no less
than annually. The company EHS department will perform periodic reviews of
permit-required confined space entry permits.
IX. Responsibility
A. Competent Person
B. Entry Supervisor
C. PIC
D. Facility Manager
E. EHS Manager
X. Refer ence
EHS-F-316 Confined Space Entry Permit
EHS-WI-339 Completing the Confined Space Permit

44
EHS Standar d #6 Hazar d Communication (HAZCOM) Right to Know
Pur pose
Establish a standard for communicating, using, and handling chemicals existing in the
workplace. To ensure that all employees exposed to hazardous chemicals are aware of the
specific hazards presented by these chemicals and are trained to protect themselves from
the dangers that exposure to these chemicals might present.
Definitions
Chemical: Any element, compound or mixture of elements
and/or compounds; this includes solids, gases and
liquids

Hazardous Chemical: A chemical posing a physical or health hazard

Health Hazard: A chemical for which there is statistically significant


evidence, based on at least one study in accordance
with established scientific principles that acute or
chronic health effects may occur in exposed
employees.

Label: Written, printed, or graphic material displayed on or


affixed to a container.

Material Safety Data Sheet (MSDS): A document containing chemical hazards and safe
handling information that is prepared in accordance
with the requirements of the OSHA standard for that
MSDS.

Personal Protective Equipment: Protective equipment worn to prevent occupational


injury or illness; safety glasses, gloves, respirators,
steel-toed boots, etc.

Physical Hazard: A chemical for which there is scientifically valid


evidence that it is a combustible liquid, a compressed
gas, an explosive, an organic peroxide, an oxidizer, a
pyrophoric or that it is flammable, unstable (reactive)
or reacts violently when in contact with water.

45
Pr ocedur e
I. Requir ed Labels
A. Each chemical container on Company offshore property/vessel shall have a
Hazard Communication label on it. Subject to state law, the Hazard
Communication label may have either a basic hazard index or NFPA
(National Fire Protection Association) label 704.
B. Chemical labeling must list, at a minimum all of the
following information:
Name and address of supplier or manufacturer
Chemical identity (obtainable from original label and
MSDS sheets)
Appropriate hazard warnings (words, pictures, or
symbols which convey hazard(s) of chemical in
container)
Hazard Communication labels must be legible and in
English.
C. Exceptions to required labeling:
When an employee transfers a chemical to a portable
container, which is intended for use only during that
employees work shift, a hazard communication label is
not required. However, the container must remain under
the control of the employee who made the transfer and
the product content must be identified on the container.
Piping is also exempt (with the exception of some
states).
II. Chemical Inventor y List
A. Each (Site Supervisor, Captain and Department Manager) shall compile and
maintain an active inventory list of all hazardous chemicals used or stored in
their work place. The inventory shall be modified as new chemicals are
received. Chemical inventories will be kept in the front of the MSDS book.
III. Mater ial Safety Data Sheets (MSDS)
A. Company employees or representatives shall not accept chemical deliveries
without an MSDS. This includes chemicals delivered in house from
company inventory to vessels and facilities.
B. The company employee or representative who initially takes delivery of the
chemical shall be responsible for obtaining and forwarding the MSDS to the
supervisor or person in charge so that it may be filed in the MSDS book.
C. If any information is missing on the MSDS, the shipping and receiving
46
coordinator or supervisor must request a revised MSDS from the vendor.
D. The Site Supervisor shall review all MSDS and distribute approved/revised
chemical MSDS to applicable supervisors.
E. The supervisor is responsible for distribution of MSDS to his personnel. The
MSDS are to be placed in the MSDS book or added to the database where
applicable. In either case, MSDS should be easily accessible at each work
location.
F. When material is transported, a copy of the MSDS must be transported with
the material.
G. MSDS may be used as a type of exposure record. The company Human
Resources Department shall maintain a retention file of these exposure
records. The retention file shall also contain copies of all directives and
correspondence regarding these chemical exposures. Each MSDS in the
retention file must be maintained for at least 30 years.
IV. Tr aining
A. Training will include Basic Hazard Communication. Employees will be
trained in the use of hazardous chemicals initially or whenever a new chemical
is introduced. Training for new employees will be conducted during new hire
orientation.
V. Tr aining of Employees for Non-Routine Tasks
A. Prior to start of any non-routine work, all employees who will be performing
such work should seek information from their supervisor regarding the
following:
Hazards involved in non-routine tasks associated with
the work to be performed, i.e., confined space entry.
Hazards of chemicals in unlabeled pipes.
Nature of hazardous chemicals expected to be
encountered.
Hazards associated with these chemicals.
Required personal protective equipment and/or safe
work practices.
Applicable MSDS.
VI. Infor ming Subcontr actor s of Hazar ds
A. The company Offshore Supervisor on location or company Offshore Field
Employee will inform the contract employee supervisor of any hazardous
chemicals which they may be exposed to during their service on company
offshore properties.

47
B. Information must include the following:
Precautions to lessen the risk of exposure to
subcontractors.
Preventative measures taken by company to lessen total
risk of exposure.
Location of MSDS.
Emergency procedure to follow if exposed.
Product labeling.
Subcontractor supervisor responsibilities under this
policy include:
1. Explanations of work practices and personal
protective equipment necessary to safely
handle each of the subcontractors chemicals
or substances used or stored on location by
any personnel.
2. Providing company Supervisors with the
manufacturers MSDS for each hazardous
material brought on location.
3. Explanations of work practices and personal
protective equipment necessary to safely
handle each of the subcontractors chemicals
or substances used on location by any
personnel.
VII. Responsibility:
A. Department Manager
B. Vessels Master/Captain/Superintendent
C. Site Supervisor
D. All employees
VIII. Exhibit
National Fire Protection Association (NFPA) Label & Hazardous Index Label

48
Name:

4 = SEVERE HAZARD
HEALTH 1 3 = SERIOUS HAZARD
2 = MODERATE HAZARD
FLAMMABILITY 3 1 = SLIGHT HAZARD
0 = MINIMAL HAZARD
REACTIVITY 2
PERSONAL PROTECTION

2
0 4
HMIS

49
EHS Standar d #7 Respirator y Protection
Pur pose
To provide employees respiratory protection from airborne work place contaminants when
it is not feasible to control exposures through the use of engineering controls and work
practices.
Definitions
Cartridge Type Respirator: A negative pressure air-purifying respirator whereby
air is drawn through a filter by the wearers
breathing action causing a negative pressure inside
the mask. This type of respirator is for site-specific
jobs only. Review of exposures and use limitations
must be done prior to use.

Contaminants: Toxic gases, harmful dusts, fogs, fuels, mists, gases,


smokes, sprays or vapors, when such contaminants
are above their permissible exposure level.

Immediately Dangerous to
Life and Health (IDLH)
Atmosphere: An atmosphere that contains a toxic contaminant(s),
which has the potential to cause adverse health
effects or death should the worker inhale the toxic
contaminants.

Negative Pressure F ield


Fit Test: A test to ensure initial face-to-respirator seal
effectiveness. The wearer dons the respirator,
performs a negative pressure test by closing off all
air inhalation points and takes a normal inhalation
breath. The respirator will collapse toward the
wearers face if the seal is secure.

Negative Pressure
Respirator: A respirator that uses a cartridge, canister or a single-
use dust mask to remove specific contaminants from
the air drawn through the cartridge, canister or dust
mask. This type of respirator may only be used after
the wearer has passed an annual respirator fit test and
then only upon the approval of the Site Supervisor.

50
Self-contained Breathing
Apparatus (SCBA): A respirator equipped with a regulator assembly
capable of providing positive pressure to the air mask
and having an air cylinder with at least 30 minutes air
supply. This respirator unit is commonly referred to as
a Scott Air Pak.

Stand-by Person: A person who is trained to provide emergency


assistance, whose sole duty is to monitor and assist a
person using a respirator in an IDLH Atmosphere.

Supplied Air Respirators (SAR): Supplied-air respirator (SAR) or airline respirator


means an atmosphere-supplying respirator for which
the source of breathing air is not designed to be carried
by the user.
Pr ocedur e
I. Respir ator
A. A supplied air respirator and/or self-contained breathing apparatus will be the
respirator of choice for protection from toxic gases, harmful dusts, fogs, fumes,
mists, gases, smokes, sprays or vapors when such contaminants are above their
permissible employee exposure level. (Reference the MSDS for the particular
permissible employee exposure level). (Refer to EHS Standard #6 Hazard
Communication).
B. Negative pressure (Half Mask Air Purifying Respirator) type respirators may be
used for most tasks as approved by the Site Supervisor. This type air-purifying
respirator shall be worn during all spray-painting operations and when using
solvents and cleaning fluids as directed on the MSDS. The North 5500 and 7700
series respirator is available for these tasks through the company warehouse.
Always refer to the operating and maintenance instruction manual for the
selected respirator. This type air-purifying respirator shall not be worn in
atmospheres where the concentration of the contaminant is immediately
dangerous to life, to health or where toxic air contaminants exist.

51
Air-purifying elements (cartridges) are color coded to protect against the specific exposures
i.e.,

Color Filter Type Color Filter Type

Black Organic vapors White Acid Gases

Ammonia and
Yellow Organic/Acids Green
Methylamine

Gold/Black Pink P-100 Particulate


Organic/Formaldehyde
P-100 Particulate/ Organic
Gold Multi gas and vapors Pink/Black
Vapors
Pink/Yellow Organic Vapors/Acid Pink/White Acid Gases/P 100
Gases/P100 Particulate

Pink/Green Ammonia/ Pink/Gold/ Organic/Formaldehyde/ P


Methylamine/P 100 100 Particulate
Black
P 100 Pancake Particulate
Pink/Gold Multi Gas/Vapor/P 100 Pancake
Filter

When painting a pr e-filter pad should be installed to pr otect the air -pur ifying
elements.
II. Car e of Respir ator s
B. The users before and after each use will inspect respirators. Inspection
shall consist of checking tightness of connections, condition of face
pieces, head band, valves, canisters and rubber parts. Supervisors shall be
made aware of respirators needing repair or replacement. Supervisors
must provide spare equipment. Before each use, the user shall perform a
field respirator fit test.
Respirators with any defects shall not be worn.
Respirators that are permanently issued to employees shall
be kept clean and in good working order by that
employee. If signs of wear-and-tear begin to show, the
respirator must be returned to the supervisor and
exchanged.
Store respirators will be inspected after each use or at least
52
monthly by the supervisor of the users department. Any
irregularities that are found will be corrected.
The user of a respirator is responsible for cleaning and
decontamination of respirator after each use.
The SCBA shall be thoroughly inspected after each use
and at least once a month.
Change filter as per manufacturer recommendations. If the
employee detects vapor or gas breakthrough, changes in
breathing resistance, or leakage of the facepiece, the
employer must replace or repair the respirator before
allowing the employee to return to the work area.
III. Use of Respir ator s
A. Prior to use of any respirator, a tight facial seal must be obtained which is then
checked by a field respirator fit test. This is the responsibility of each individual
user.
B. Respirators shall not be worn under certain conditions: Facial hair, absence of
dentures, sideburns, eyeglass temple pieces, etc. prevent a good face seal.
C. The following is required prior to using respirators where an atmosphere is or
has potential to become Immediately Dangerous to Life and Health (IDLH):
Refer to and review any written procedures for a specific job i.e., (H2S, Permit-
Required Confined Space Entry Standard, etc.)
E. The following are key considerations when preparing for work in an IDLH
Atmosphere:
1. Type of respirator to be worn
2. The employer shall provide the following respirators for employee use in
IDLH atmospheres:
a. A full face piece pressure demand SCBA certified by NIOSH for a
minimum service life of thirty minutes, or
b. A combination full face piece pressure demand supplied-air
respirator (SAR) with auxiliary self-contained air supply.
c. Respirators provided only for escape from IDLH atmospheres shall
be NIOSH-certified for escape from the atmosphere in which they
will be used.
d. All oxygen-deficient atmospheres shall be considered IDLH.
3. Toxic atmosphere potential

53
4. Communication techniques to be used
5. Basic rescue equipment/devices needed
F. While working in an IDLH atmosphere, a stand-by person must be present at all
times and positioned outside the IDLH Atmosphere. Communications by voice,
visual or hand signal must be maintained between the stand-by person and the
worker in the IDLH Atmosphere.
G. A Supplied Air Respirator or SCBA shall be available for stand-by person.
H. Means of communication or transportation must be available on-site for
emergencies.
I. Rescue equipment (lifelines, lifting harnesses, winching devices or the
equivalent) must be used when other assistance is not immediately available.
J. H2S presents an IDLH Atmosphere when concentrations of gas are suspected or
known to be >100 ppm.
IV. Tr aining
Employees shall be trained prior to performing a job that requires a respirator.
Refresher training is required annually. The company Training department will assist
in training facilitation as requested.
V. Respir ator Medical Evaluation Questionnair e
A. Any employee required to wear a respirator any time during a calendar year
must complete a Respirator Medical Evaluation Questionnaire.
B. A licensed physician shall determine whether use of a respirator could put an
employee at increased risk, due to medical impairment shall evaluate all
questionnaires.
C. Questionnaires shall be obtained from Human Resources and shall be returned
following physician evaluation.
VI. Recor d Keeping and Access to Recor ds
A. The following records shall be maintained in this plan:
A list of employees who are required to wear respirators.
The Human Resources Department will maintain records.
Training records for employees in Respiratory Protection
Standard. The Human Resources and Training
Department will maintain records.
Respirator inspection records. The vessel or facility
manager shall keep the records of inspection.

54
VII. Respir ator y Pr otection Evaluation
A. The EHS Department shall review this standard annually for
effectiveness.
B. Review to consist of:
Selection and use of respirators appropriate for job task.
Documentation of training.
Confirmation that all job tasks requiring respirators have
been identified.
C. Consult with employees to identify problems with equipment.
D. Site Supervisor shall frequently inspect the work place to ensure that
respirators are cleaned and maintained properly.
VIII. Responsibility
A. Site Supervisor
B. Program Administrator
C. Human Resources Department
D. Training Department

XI. Refer ences


EHS-P-337 Respiratory Protection
EHS-I-337 Respiratory Equipment Inspection

55
EHS Standar d #8 Solid Waste Management
Pur pose
To provide a system for identification, classification, economic minimization, handling and
disposal of all solid wastes generated by company operations through development of a Solid
Waste Management Plan and to ensure documentation of waste management from generation
to final disposal.
Definitions
Hazardous Waste: Any solid waste which is listed as hazardous by
RCRA, Subtitle C, or which has been mixed with or
exhibits the characteristics of hazardous waste.

Hazardous Waste Characteristics: Specific characteristics identified by RCRA in Subtitle


C that cause a waste to be hazardous. A waste
exhibiting any one of the following characteristics
classifies it as hazardous:
Ignitable liquid with flash point <140 or non-liquid
capable of causing fire when handled.
Corrosive liquid with pH less than 2.0 or greater than
12.5.
Reactive reacts violently with water, undergoes
violent change without detonation or detonates when
hit.
Toxic fails Toxic Character Leachate Process
(TCLP) test

RCRA: Resource Conservation and Recovery Act RCRA


(pronounced rick-rah) gave EPA the authority to
control hazardous waste from the cradle-to-grave.
This includes the generation, transportation, treatment,
storage, and disposal of hazardous waste. RCRA also
set forth a framework for the management of non-
hazardous wastes.

Reclaimed: A solid waste that is processed to recover a usable


product or is otherwise regenerated.

56
Recycled: A solid waste that is used, reused or reclaimed, as
ingredients in industrial process to make a product or
provide an effective substitute for commercial
products.

Solid Waste: Any discarded material that is abandoned, spilled or


disposed by burning, injecting down hole or land
filled; anything which can no longer be used for its
original purpose. Solid waste may be solid, semi-solid,
liquid, or containerized gas that has been discarded,
used or is a by-product.
Pr ocedur e
I. Master Waste List
A. No waste will be allowed off a vessel without a proper Bill of Lading and/or
Waste Transfer Ticket signed by an accepting company representative dockside
or by an approved waste vendor.
B. All solid wastes generated by company operations shall be recognized and
identified by the person in charge of the operations and then compiled into a
master waste list. The master waste list is located in the company EHS Manual.
C. Identification shall include declaring the source or process generating the waste.
D. Wastes shall be classified by the company EHS Department as hazardous or
non-hazardous, including methodology for determination, if classed non-
hazardous. Waste classifications and handling guidelines are located in the
company EHS Manual.
II. Waste Management Plans
A. Master waste list shall be revised as necessary and shall be reviewed annually by
the department manager.
B. The company EHS department shall prepare an individual solid waste
management plan for each waste listed on the master waste list. This waste
management plan is located in the company EHS Manual.
C. Solid waste management plans shall be approved and signed by the department
manager responsible for the operations generating the waste.
D. Preferred method of disposal shall be clearly stated and specific disposal site(s)
identified. These may be identified on each plan by name, or as an attachment to
the plan in the form of an approved list.
E. Disposal sites shall be evaluated and inspected periodically by the company EHS

57
department. Inspection frequency shall be determined by the department
manager based on owner/operator of facility, type of disposal permitted and
initial evaluation.
F. Waste shall be handled and/or stored in accordance with its specific plan.
G. Plans shall identify all records/documents resulting from management of a
specific waste.
III. Waste Disposal
A. When preparing the plans, the following shall be considered:
No waste may be disposed of without a waste
management plan.
Hazardous and non-hazardous wastes shall not be
commingled.
Final disposal may only be at a site approved by the
department manager.
Recycling is preferable to disposal.
B. Hazardous wastes require special handling. A solid waste management plan for
hazardous waste must have the signed approval of the division manager.
C. Hazardous waste disposal facilities shall be evaluated and inspected annually by
the company EHS department and area management. Observed noncompliance
or other concerns shall be communicated to the division manager. The decision
to cease disposal at any site shall require immediate revision of the plan and/or
the approved disposal site list.
D. Documentation of hazardous waste management shall be maintained
indefinitely by the operating area generating the waste.
E. Goals for waste management are identified in EHS management plans and
should address waste reduction.
IV. Tr aining
A. Shall be provided initially and as needed by each operating group with direction
from the company Training Department. Solid waste management plans shall
be reviewed whenever a plan is revised or a new plan is added.
B. Resource Conservation and Recovery Act (RCRA) training shall be provided
according to the company required training document.
V. Responsibility
Department Manager / Supervisor

58
VI. Refer ences
EHS-P-329 Waste Management Plan
SCM-F-200 Bill of Lading (BoL)

59
EHS Standar d #9 Natur ally Occur r ing Radioactive Mater ial (NORM)
Pur pose
To establish a standard for identifying, labeling, maintaining, storing and disposing of
equipment contaminated with NORM.
Definitions
Background Level: The level of NORM measured in an area where
topography is unaffected by company operations.

Equipment: All parts and equipment involved in the production of


oil and gas including tubular, above or below ground.
Licensed F acility: A NORM cleaning and/or disposal facility that has
been licensed by the United States Nuclear Regulatory
Commission or the state in which the facility is
located.
Micro Roentgens per Hour (R/hr): A measurement of exposure from x-ray and gamma ray
radiation in the air.
NORM (Naturally Occurring
Radioactive Material): Any nuclide that is radioactive in its natural physical
state (not man-made), but not including source, by-
product, or special nuclear material. NORM is most
commonly found adhering to tubulars and equipment
in the form of scale, detected by equipment measuring
R/hr.
NORM, specifically Ra-226 and Ra-228, which is
detected by analysis measuring pCi/g, is naturally
occurring in formations from which oil/gas is
produced.
NORM Action Level
(NAL): That level of NORM, which triggers full
implementation of company NORM Worker Protection
Plan and Confirmatory Survey. 50R/hr including
background in Louisiana; 25R/hr in Texas.
NORM Site Any part of a location, land area (such as a well site,
pipe yard, scrap yard, production pit, land farm, etc.),
equipment or other objects where NORM is present at
or above NAL.

60
Picocuries per Gram
(pCi/g): A measure of the radioactivity in one gram of material.
One picocurie is that quantity of a radionuclide that
decays at the rate of 2.2 disintegrations per minute.

Qualified Person: One who has documented training in the performance


of a NORM survey as required by a state or federal
agency or, when a state does not require specific
training an employee trained according to Worker
Protection Plan (Exhibit A) with knowledge of the
NORM survey process.
Waste: Scale removed from equipment or material (soil)
generated from a NORM Site remediation or
abandonment.
Pr ocedur e
I. NORM Action Level
A. The NORM action level (NAL) for equipment shall be set by applicable state
regulations, but in no case shall it exceed 50 R/hr above background.
B. Where regulations do not exist, the NAL for equipment shall be >50 R/hr
including background.
II. NORM Measur ements
A. A NORM measurement may be either a Screen or Confirmatory Survey and
shall be done in accordance with applicable state regulations and the provisions
of this standard. All NORM measurements must be done by a qualified person
to detect NORM using instruments capable of measuring micro roentgens/hour
(R/hr) as approved by federal or state regulations.
B. Screen: The initial assessment made to determine the presence of NORM.
The company Project Manager will be responsible for
identifying, through the customer, if there is a possibility
of NORM presence at the job site.
Production characteristics in the area aid in identifying a
history of NORM.
An assessment using a NORM meter is conducted on
existing equipment.
1. All abandoned equipment, pipe, valves and
junk iron shall be screened prior to being

61
transported, cleaned, sold or otherwise treated.
Equipment contaminated above NAL shall be
transported in compliance with applicable state
and federal regulations and shall be reported to
the company EHS Department.
III. Stor ag e and Tr anspor tatio n
A. Equipment, which is no longer in service and/or waste that are contaminated
above the NAL, may not be stored by The Company. At no time should
ownership of NORM contaminated equipment or junk iron be accepted
without the approval of the division manager.
B. Storage of NORM waste in the Outer Continental Shelf (OCS) requires prior
approval from the BOEMRE Regional Director.
C. Storage of NORM equipment, scrap iron or waste on behalf of customer should
be discouraged.
D. Storage of contaminated equipment shall not exceed one year from the date it is
removed from service. Storage of waste shall not exceed 90 days without state
approval.
E. Notice of Transfer of NORM contaminated equipment or waste from one
company location to another must be maintained by the EHS Department.
F. A manifest shall accompany all NORM contaminated equipment or waste when
shipped to a licensed treatment, storage or disposal facility. One copy of the
completed manifest shall be retained in the project file. As manifest
requirements vary from state to state, the company EHS Department shall verify
current procedures.
IV. Cleaning
A. No equipment contaminated above the NAL shall be salvaged or sold to any
party unless cleaned to reduce the level of contamination below the NAL.
B. Cleaning or remediation of NORM contaminated equipment or scrap iron shall
be performed only by an approved subcontractor, licensed if required by the
state where work is performed.
V. Pr otection fr om Exposur e
A. The companys NORM Worker Protection Plan shall be implemented at all
NORM sites.
B. All field employees shall be given basic NORM training once every three years.
Employees working in NORM sites shall be trained annually in procedures
outlined in the NORM Worker Protection Plan and by this operating standard.

62
C. Signs and notices shall be posted at all facilities and on equipment where NORM
levels exceed NAL.
D. Any detection of NORM shall require employees who are performing grinding,
cutting, cleaning or other work that generates dust, to protect themselves from
airborne particulate through use of a dust protection device and good personal
hygiene. (Refer to EHS-P-307 & EHS Standard #1 PPE and EHS-P-337 & #7
Respiratory Protection).
VI. Recor d Keeping
A. The EHS Department shall maintain results of NORM Screen and Confirmatory
Survey for a period of 30 years.
B. The EHS Department shall maintain NORM Manifests or Material Transfers for
movement of contaminated equipment or waste.
VII. Subcontr actor s
All subcontractors shall be advised of and shall comply with this operating standard.
VIII. Tr aining
All field employees upon hire and as needed.
IX. Responsibility
A. Project Manager
B. Site Supervisor
C. Area Managers
X. Exhibits
Exhibit A: Company Worker Protection Plan for Naturally Occurring Radioactive
Material (NORM)
XI. Refer ences
EHS-P-336 NORM Procedure
EHS-F-336 NORM Confirmatory Survey Report

63
EXHIBIT A
COMPANY WORKER PROTECTION PLAN
NATURALLY OCCURRING RADIOACTIVE MATERIAL (NORM)
Gener al
Work which requires the removal or dismantling of NORM contaminated equipment or
piping may cause employees to have direct physical contact with NORM-contaminated sand,
scale and sludge.
I. Scope
To minimize potential internal exposure, the following work practices shall be
followed when handling dismantled NORM equipment/waste, working at a NORM site
or when entering vessels, which may be contaminated with NORM.
II. Wor king with NORM-Contaminated Mater ials
A. Employees and subcontractors shall be advised of the presence and potential
hazards of NORM and of the procedures to minimize exposure.
B. Company NORM Standard and this Worker Protection Plan shall be reviewed
prior to work activities.
C. Eating, drinking, smoking, chewing or applying cosmetics (e.g., sunscreen, lip
balm) shall not be allowed in the immediate work area of NORM-contaminated
equipment.
D. Openings on NORM-contaminated equipment shall be capped, wrapped or
sealed, in plastic to minimize the generation of any dust or the displacement of
scale or sludge that may contaminate the surrounding soil.
E. Personal radiation exposures at NORM-contaminated sites shall be evaluated
through the use of personal dosimeters where personnel are likely to receive
greater than 312.5 millirem per calendar quarter. This equates to full-time
exposure of 600 R/hr for a 40-hour week.
F. When moving, handling or transporting tubulars or other open equipment that
has been identified as NORM-contaminated, personnel shall wear protective
boots, gloves and coveralls to minimize contact with NORM.
G. Loose NORM scale and sludge materials shall be kept wet to minimize dust
generation during handling.
H. When performing activities on contaminated equipment that has the potential to
generate airborne particulates (grinding, cutting, sandblasting, drilling,
polishing, welding), the following precautions shall be taken:
Protective clothing shall be worn. A respirator, either
full-face, supplied air or half-face, approved for

64
radionuclides shall be worn. A half-face respirator must
have a High Efficiency Particulate Air (HEPA) rated
cartridge approved for radionuclide dust. These
cartridges have a magenta or hot pink color code.
Appropriate eye protection shall be worn.
Temporary, plastic ground covers shall be used when or
where necessary to contain any displaced NORM
contamination.
Personal monitoring equipment shall be employed if
determined necessary by total dose exposure. Bioassay
shall be performed if needed.
Activities shall be conducted in access-restricted, well-
ventilated areas.
I. After working on contaminated equipment, personnel shall wash their hands
and face before eating, drinking, smoking, chewing or applying cosmetics to
prevent ingestion of NORM.
J. The number of personnel in a NORM storage area shall be kept to an absolute
minimum.
III. Pr ocedur es for Enter ing a NORM-Contaminated Vessel
A. In addition to company Confined Space Entry Standard #5, personnel entering a
vessel that is considered to be contaminated above NAL shall adhere to the
following procedures:
The vessel shall be ventilated at least four (4) hours before
entry to allow the decay of short-lived radon gas to
insignificant levels.
Personal protective equipment shall include latex rubber
or neoprene gloves, rubber work boots, rubber slicker suit,
a respirator with High Efficiency Particulate Air
cartridges or a self-contained breathing apparatus.
Personal radiation exposures associated with vessel entry
shall be evaluated.
B. Contaminated gloves, respirators, coveralls, boots, cleaning rags and tools shall
be decontaminated by rinsing off with soapy water or laundered. Care shall be
taken to avoid ground contamination by wash water. If decontamination is not
possible, materials shall be placed in double bags, sealed and held for disposal as
NORM Waste according to company Waste Management Plan. No contaminated

65
equipment or materials shall leave the site unless properly sealed. (Refer to EHS
Standard #8 Solid Waste Management).
IV. Signs and Notices
A. A permanent sign identifying a company contact and phone number shall be
conspicuously posted at sites where NORM-contaminated material is stored. The
contact must have access to and be familiar with records required in Part VI of
this NORM Standard.
B. NORM-contaminated equipment/tubulars and containers of NORM waste shall
be tagged or labeled similar to the following:
Warning Naturally Occurring Radioactive Materials
C. A single label is sufficient for a stack of stored tubulars if the total came from
the same site. Labels on stored material shall also have identification numbers
that correspond with company records specific to contaminated material,
V. Tr aining
A. Will include initial training, a general overview on annual basis and training as
needed to address specific exposures on a job/task basis.
VI. Recor d Keeping
A. Documentation required by the company shall be maintained in addition to the
following records:
1. Surveys of NORM storage area.
2. Radiation exposure data for individuals if required to wear personal
monitoring equipment.
3. Training documentation.
4. All permits to work

66
EHS Standar d #10 Wor king at Height (Climbing & Fall Pr otection)
Pur pose
To establish minimum fall protection requirements for personnel working where fall hazards
exist.
Definitions
Competent Person: One who is trained and certified capable of identifying
hazards in the surroundings or working conditions, and
has authorization to take prompt corrective action.

Personal Fall Arrest


System: A system used to arrest an employee in a fall from a
working level.

Free Fall: The act of falling before a fall arrest system begins to
apply force to arrest a fall.

F ull Body Harness: A harness designed with straps that will secure about
the employee in a manner that will distribute the force
of a fall over at least the thighs, pelvis, waist, chest and
shoulders with the means of attaching it to other
components of a personal fall arrest system.

Lanyard: A flexible line, rope or strap, which generally has a


connector at each end for attaching to the body harness
and a shock absorbing/deceleration device and anchor
point.

Locking Snap Hook: A connector consisting of a hook-shaped member with


a self-closing, self-locking keeper that remains closed
and locked until it is unlocked and pressed open for
connection and disconnection. This is sometimes
referred to as a double-locking snap hook.

Lifeline: A component consisting of a flexible line for


connection to an anchorage point at one end to hang
vertically or connected to anchorage points at both
67
ends to stretch horizontally, and which serves as a
means for connecting other components of a personal
fall arrest system to the anchorage.
Self-Retracting Lifeline: A deceleration device containing a drum-wound line
which can be slowly extracted from, or retracted onto,
the drum under slight tension during normal employee
movement and which, after the onset of a fall
automatically locks the drum and arrests the fall.

Scaffolding: Any metal, tubular or frame including such as braces,


brackets, boards, planks, trusses, legs, ladders, etc.,
erected for the purpose of access or a working surface.

Pr ocedur e
It is mandatory that anyone 6 feet or more above a working surface or within 6 feet of a
leading edge shall use a fall protection system 100% of the time. All tasks requiring an
employee to work at a height of 6 feet above a surface or within 6 feet of a leading edge not
protected by handrails or working over water not protected by handrails shall obtain a
Working at Height Permit (Refer to EHS-P-320 and EHS Standard #13 Permit to Work).
I. Wor king at Height Per mit
A. The supervisor and the person(s) performing the task must fill out the permit.
B. The permit is valid for 12 hours or end of shift, whichever occurs first.
C. Any unscheduled work stoppage, unforeseen hazard or emergency condition
nullifies this permit.
D. All requirements of the permit must be met prior to start of work.
E. The completed permit will be turned in with the job paperwork or maintained at
the facility/yard.
II. Fall Pr otection for Unpr otected Sides, Edges and Wall Openings
A. Personnel working six (6) feet or more above a lower level shall be protected
from falling by the use of a guardrail system, fall arrest system or safety net.
B. Stairways, ramps, runways or other walkways four (4) feet or more above a
lower level shall be protected by a guardrail system on all sides.
III. Per sonal Fall Pr otection Systems
A. When an employee is working in an area where there is a potential to fall six (6)
feet or more, approved fall protection shall be used. This includes, but is not

68
limited to, a full body harness and a lifeline, lanyard, deceleration device or
positioning device.
B. When working outside of railing and over water, both fall protection equipment
and a personal flotation device must be worn.
C. Persons using a personal fall arrest system shall practice 100% tie-off (being
protected from falls at all times). This will be achieved by use of a double strap
lanyard or a self-retracting lifeline.
D. The maximum free fall distance of six (6) feet should never be exceeded, as this
would cause a greater arresting force on the employee. To assure that the six (6)
foot maximum free fall is not exceeded, always tie-off to a point at or above the
harness D-ring.

If the safety factor in the above diagram cannot be met an alternative system must be use i.e.
self-retracting lifeline etc.
A. Tie-off using a knot in a lanyard or lifeline can reduce its strength up to 50%.
This practice should be avoided.
B. Never tie-off where the line passes over or around sharp or rough edges. Sharp
or rough edges can damage or reduce the strength of the lanyard or lifeline.
IV. Ladder s; See section General Safety, Ladders in this Manual & EHS-P-327
69
V. Rescue
A. Any time an employee uses fall protection, a means of prompt rescue must be
provided.
B. Rescue plans must be addressed in the HIRA/JSAs and communicated to all
employees affected.
VI. Tr aining
A training program will be provided for each employee who may be exposed to fall
hazards. The program shall enable each employee to recognize the hazards of falling
and shall train each employee in the procedures to minimize these hazards.
VII. Responsibility
A. Line Supervisor
B. Employee working aloft
VII. Refer ences
EHS-P-320 Working at Height Procedure
EHS Standard #13 Permit to Work
EHS-F-315 Working at Height Permit

70
EHS Standar d #11 Hazar d Identification & Risk Assessment
Pur pose
To establish a formal process to identify hazards, which are potential causes of harm,
associated with the job/tasks. Identify measures to eliminate the hazard or control an
unacceptable hazard. Record results and implement control measures at the work site. To
ensure that residual risks are as low as reasonably practicable.
Definitions
Low Risk: Identified as L in the matrix. No further immediate
action is required. Proceed with care.

Medium Risk: Identified as M in the Matrix. Hazard to be


investigated with view to reduce risk further.

Unacceptable Risk: Identified as H in the matrix. Task must not be


undertaken. Immediate actions to eliminate hazard of
substantially reduce risk by further/better control
measures.

Highly unlikely: So inconceivable that occurrence may never be


experienced during the project.

Unlikely: Improbable but just possible to occur during the


project.

Occasional: May occur some time during the project.

Likely: Probable and liable to occur more than once during the
project.

Highly likely: May occur frequently during the project.


Procedure
I. Risk Assessment Pr inciples
A. Risk Assessment shall be performed prior to any work commencing by all
71
project teams, departments and units and on all work sites where hazards have
been identified or potential hazards are thought to exist.
B. Risk Assessments should be kept short, simple and must be documented.
C. Personnel participating in the Risk Assessment should be identified in the
record.
D. Risk Assessments must be conducted in a systematic fashion using the steps in
part V of this section.
II. Timing of Risk Assessments
A. The Risk Assessment should be conducted in advance of the work activity to
allow the control measures to be correctly implemented. (This may involve
reviewing previous Risk Assessments for routine activities.) Risk Assessments
should be undertaken prior to:
performing any non-routine activity,
performing a new task,
when new people are involved,
when third party people are involved,
when major changes to the work/system are considered.
III. Stages of Risk Assessment
A. Three stages of risk assessment are carried out during project execution.
Stage 1 is usually conducted by project managers and
personnel who have ownership of the
procedures/tasks/equipment including persons competent
in conducting risk assessments. The assessment is carried
out during the project/equipment design or engineering
phase sufficiently well in advance of the work to allow
adequate lead-time to providing specialized equipment,
which will reduce the risks. The target should be to ensure
all aspects of the work have been assessed, hazards have
been identified and control measures identified before
going to the work site, such that all risks are made as low
as reasonably practical.
Stage 2 is a review of the Stage 1 risk assessment carried
out by the personnel directly involved in the activities
using the documented results of the Stage 1 assessments.
It is primarily instigated to confirm full understanding of
the work and control measures to be implemented but
72
may, in special circumstances, be used to further assess
details of the work not covered or that have changed since
the Stage 1 risk assessment.
Stage 3 is Toolbox/J SAs and are given by the
supervisors to the personnel, directly under their control
who will be conducting the work activities. Again
reference should be made to the previously recorded Stage
1 and Stage 2 assessment records and the purpose of
ensuring all personnel fully understand the work, the
control measures, and their responsibilities in executing
them. It also serves as a final check that no unforeseen
hazard exists. Team members shall have an opportunity to
ask questions about these issues. Toolbox/JSAs shall be
carried out as part of shift change or as part of specific
pre-job activities. The relevant job/task plan together with
relevant Permits to Work shall be part of the
Toolbox/JSA. The Toolbox/JSA form shall be used, and
names of participants listed on the form. There is a degree
of flexibility in how Stage 2 and Stage 3 assessments are
carried out at the work site; for example, they may be
combined if all personnel attended the shift briefing. It is
important that everyone involved in the job is fully aware
of, accepts the risks of, and accepts the control measures
to be implemented during the work process.
IV. Detailed Risk Assessment (HIRA)
A. The Hazard Identification and Risk Assessment procedure is comprised of 6
key steps. The following section outlines the exact steps to follow when
completing the Hazard Identification and Risk Assessment Record.
1. Step 1: Task Identification
a. Identify the task. Record on risk assessment form.
b. Does an existing risk assessment fully match this scope of work?
i If yes Proceed to Step 4. Re-quantify the risk with
appropriate controls.
ii If no Continue to C.
c. Does an existing risk assessment partially match this scope of
work?
i If yes Identify valid tasks and complete risk assessment
form.

73
ii If no continue to D.
d. Identify tasks and go to Step 2.
2. Step 2: Hazard Identification
a. Develop a list of tasks. Record on risk assessment form.
b. Identify hazards applicable to each task. Record on risk assessment
form.
c. Verify list Does it address all hazards?
i If yes Proceed to Step 3.
ii If no continue adding to hazard list.
3. Step 3:Who/What might be harmed
a. Identify who/what might be harmed. Record on risk assessment
form.
b. Verify list Does it address all hazards?
i If yes Proceed to Step 4.
ii If no continue adding to Who/What list.
4. Step 4: Quantify the Risk

RISK CRITERIA (ALARP = As Low As Reasonably Practicable)

Operations can proceed without further controls. Consider any


Low Risk cost benefits which can be achieved.
L
1-10

May need further consideration or unacceptable risk reduction


Medium Risk measures / contingency plan being applied to achieve ALARP.
M
11-19

HIGH - Operations must not proceed. Alternative methods or risk


Unacceptable Risk H reduction measures must be developed.
20-25

PROBABILITY GUIDELINES

A possible event but never experienced. Extremely remote chance of this


Highly Unlikely
occurring.

Unlikely An event is not likely during operations or equipment design life.

74
An infrequent event that may occur during operations or equipment
Occasional
design life.

An event that is likely to occur one or more times during operations or


Likely
equipment design life.

Frequent A common event that is likely to occur one or more times a year.

CONSEQUENCE TABLE PROBABILITY

Descrip Safety Environ Highly Occasio Frequen


Material Unlikely Likely
tion or ment or Unlikely nal t
Damage 2 4
Value Injury Pollution 1 3 5
Major Lost
Very spill and asset/
Multiple
Serious escape to Abandon 15 19 22 24 25
Deaths
E the ment /
i L f
Possible Spill Severe
Death with damage
Serious
Multiple severe to asset / 10 14 18 21 23
D
severe escape to extended
Injuries the loss of
Modera Possible Spill Significa
te - Severe with nt
Signific Injury significa equipme 6 9 13 17 20
ant Multiple nt escape nt
C Minor to the damage /
Spill Minor
Slight - Possible with equipme
Minor Minor minor nt 3 5 8 12 16
B Injury escape to damage /
the one day
Spill Minor
Negligi No with no equipme
ble Potential escape to nt 1 2 4 7 11
A for injury the damage /
environm no delay
HAZARD EXAMPLE OUTCOMES (examples of injury or harm)

Manual Handling Overexertion/repetitive Sprains, strains, fractures


motion

Falls Falling objects, falls, slips Fractures, bruises, lacerations, dislocations,


and trips of people concussion, permanent or fatal injuries

Electricity Electric current, lightening Shocks, burns, electrocution

Moving or Rotating Being hit, hitting objects, Cuts, bruises, dislocations, fractures, amputation,
Machinery & equipment being caught in or between, permanent or fatal injuries
over-turning vehicles
Equipment Failure Crane fails, rigging fails, Injuries, fatalities, damage, miss direction
communications fails

Hazardous substances Chemicals such as acids, Toxic effects, dermatitis, respiratory illnesses, cancer
hydrocarbons, heavy metal

Extremes of temperature Effects of heat or cold Burns, frost bite, heat stress, heat stroke

Noise Excessive noise Permanent hearing damage

75
Light Intense light or lack of Burns or blindness
illumination Falls, Cuts, bruises, dislocations, fractures,
amputation, permanent or fatal injuries
Radiation Ultra violet, welding arc Burns, cancer, damaged eyesight, blindness
flashes, micro waves, lasers

Biological Viruses, bacteria, fungi, Hepatitis, Legionnaires disease, Q fever, tetanus,


toxins HIV/AIDS, allergies

Vibration Hands and whole body Organ, nerve and muscle damage

Psychological stress Intimidation, organizational High blood pressure, headaches and migraine,
change, violence, conflict, anxiety, depression, absenteeism
time pressure

5. Step 5: Control Measures


a. List control measures for each identified hazard (Risk Assessment
form). Include controls as contingency for process failure(s).
b. Compare control measures against standard criteria. Record
conclusion in R.A. form.
c. Implement task and monitor effectiveness of safety precautions.
Add to R.A. form.
d. Priority must be given to those risks, which affect large numbers of
people and/or could result in serious harm. The principles below
should be applied when taking further action: (preferably in order)
i Remove the Risk completely
ii Evaluate alternative methods/equipment
iii Organize work to reduce exposure to hazard
iv Prevent access to the Hazard (e.g. by guarding).
v Issue PPE
vi Provide equipment/facilities (e.g. washing facilities for
removal of contamination)
6. Step 6: Residual Risk
a. Re-quantify the risk (Step 4) with control measures in place.
b. Are the residual risks acceptable?
i If yes Compare control measures against standards. Record in
R.A. form.
ii If no Can further control measures be identified?

If yes Return to Step 6.A

76
If no STOP DO NOT PROCEED

c. Verify the following:

i Have all contingencies been addressed?


ii Have all possible situations where a snag or failure could
develop been covered?
iii Are contingency procedures established?

XII. Repor ting and Follow up


A. Reporting
On completion of a Stage 1 Risk Assessment, a written report shall be issued.
This report shall have the following contents:
1. Introduction
Scope including outline of the work tasks
The method used
2. Assessment Records
Location and date
Participants and team leader
Clear breakdown of activities
3. Recommendations
Corrective actions (including the responsible person and time
limits)
4. Appendix(ices) (as required)
a. The final report should be copied to
the project or job file and to the
EHS Department to be added to a
working file of Risk Assessments.
b. Stage 2 Risk Assessments simply
require the completed Stage 1 Risk
Assessment forms to be completed.
These may be kept in the project or
job file and onboard the ship or
barges to compliment the catalogue
of Risk Assessments for future
reference.
c. When doing a Stage 3
Toolbox/JSA, the completed form,
when relevant the Permits to Work,

77
need to be kept on record for the
life of the project then included in
the job paper work. In the event of
injury or incident, they must be
kept as a permanent record.
d. Note: The Stage 3 records are to be
turned in with the job paperwork.
The meeting and attendees should
be recorded in the daily job/status
report.
B. Follow up and close out
The person responsible for the production of the HIRA shall clearly identify who
is responsible for corrective actions and will set a time limit. The time limit shall
be scheduled sufficiently in advance of the work activities.

XIII. Tr aining
A. All employees will be trained in the levels of HIRA that they will directly
affected by or may be responsible for completing i.e. Superintendents will be
trained in all Stages of HIRA, while Lead Tenders will be trained in Stage 3.
XIV. Responsibility
A. Project Managers
B. Supervisors
C. Vessel Masters
D. All employees in supervisory positions
XV. Refer ences
EHS-P-301B Project Risk Assessment HIRA Procedure
EHS-P-347 JSA Procedure

78
EHS Standar d #12 Incident and Injur y Repor ting & Investigation
Pur pose
To ensure reporting and investigation of incidents as soon as practical by the appropriate
level of company management. Each investigations objective will be the prevention of
similar incidents and the preservation of facts and information concerning the investigated
event.
Definitions
Incident: Occurrences or situations that involve a breach of
safety rules, injury, loss or any level of response.
F ormal Investigation: Fact finding process for reporting and determining
gravity of a First Aid, Near Miss or Non-Regulated
Spill or Release.
Near Miss Incidents/occurrences, which with reasonable
probabilities, could have developed into an injury or
property damage.
Regulated Spill or Release: A spill or discharge of any content or volume that
requires verbal and/or written notification to a federal,
state or local agency.
Non-Regulated Spill
Or Release: A spill or discharge which requires completion of a
company Incident Report, but is not reportable to a
federal, state or local agency.
Initial Report: The initial form completed to document an incident:
(i.e., Property Loss Report, Spill/Release Report,
Emergency Report, Reportable Event Report,
Occupational Injury Report, Automobile Loss Notice).
Incident Investigation
Report: Report to be completed when conducting a formal
investigation.
Loss Time Incident: Any work-related injury or illness which results in the
affected party not being able to work their next regular
scheduled work shift.
Medical Treatment: Any work-related injury or illness that requires
treatment by a physician but does not result in work
duty restrictions or lost work days. Does not include
first aid treatment, even though provided by physician
or registered professional person.

79
F irst Aid: Any work-related injury or illness that is minor in
nature and can be treated at the work site or by a
physician in a single visit which do not ordinarily
require medical care.
Recordable Incident: Any injury or illness that has been determined by the
EHS department to meet the OSHA guidelines
requirement for recordable cases.
Restricted Duty: Any work-related injury or illness that results in an
employee being restricted from performing any aspect
of his/her job description.
Division Manager: The highest ranking manager of a division, usually
with reporting responsibility to the EHS Steering
Team.
Media Event: An incident of a magnitude or nature that could attract
news coverage by print, radio or television media.
Pr ocedur e
I. Initial Incident Assessment
A. The senior employee at the scene of an incident is responsible for the assessment
of the gravity of the incident and the general condition of the site involved.
B. If the incident is of a more serious nature, the following actions must be taken in
the order listed:
1. Any injured persons must be cared for immediately.
2. The area should be inspected for unsafe conditions that could contribute to
additional injuries or damages. Any unsafe conditions should be
neutralized only if no one is exposed to any risks of injury in doing so. If
unsafe conditions cannot be neutralized, the area must be abandoned and
posted as being unsafe until the appropriate personnel and equipment can
be assembled.
3. Depending upon the seriousness of the incident, initial notifications and
reports should be made as outlined in the company Incident Reporting
Matrix (reference A). (NOTE: any spill or release to the water must be
reported immediately, as notification must be made to government
agencies.)
4. Any physical evidence of the incident must be preserved, as well as names
and addresses of witnesses.
C. Once the initial assessment has been made, the senior employee at the site shall
remain at the site until relieved by a management-appointed designee, or there is
80
no longer any danger to property and/or persons by leaving the site.
II. Repor ting
Verbal and written reporting an incident or injury in the workplace will follow
this procedure.

Verbal reports should be made to the following;


There will be a CAL DIVE EHS MANAGER on-call 24 hours per day, 365 days
per year.
The On Call EHS Manager and Back-up contact will be noted on the Weekly On
Call Directory.
or
CAL DIVE main office numbers, IE., Phone No.: + 1 713 361 2600 (Cal Dive
Houston Main Number) or Logistics Office LA ( 24/7 ) +1-337-857-6178, Tell
the person who answers, you are with CAL DIVE and have an emergency
situation, you will be connected to the ON-CALL EHS MANAGER who will
assess the situation and contact emergency assistance and start internal company
notifications.

(NOTE: any spill or release to the water must be reported immediately, as


notification must be made to government agencies.)

The Incident Report should be completed as soon as possible after the incident.
Routing of the Incident Report shall follow instructions on the form or the
electronic work flow for the SharePoint form. All Incident Reports must be
submitted to the company EHS Department no later than 24 hours following the
incident.

III. Infor mal Investigation


A. The following incidents shall require, at a minimum, an informal investigation,
which shall be satisfied with completion of the company Incident Report.
1. First Aid
2. Near Miss
3. Non-Regulated Spill
B. The Incident Report shall be completed by the persons noted below:
1. All injuries Company Supervisor
2. Near Miss Persons involved , company employee or witness
3. Non-Regulated Spill or Release Employee who discovers spill/release or
first Cal Dive employee/supervisor notified.

81
C. Unless otherwise expanded as set forth below, this level of the
supervisor/manager and Operations Manager of the associated division will
review investigation. Site Supervisors, at their discretion, may conduct a more
formal inquiry to obtain additional information regarding the incident. The
division manager shall maintain the discretion to elevate a review of any incident
to a formal investigation.
D. The Incident Report should be completed as soon as possible after the incident.
Routing of the Incident Report shall follow instructions on the form. All Incident
Reports must be submitted to the company EHS Department no later than 24
hours following the incident.
III. For mal Investigation
A. The following incidents shall require a formal investigation:
1. Property or Equipment Damage >$5,000**
2. Regulated Spill or Release
3. Near Miss**
4. All Vehicle Damage**
5. Explosions or Fires*
6. Serious Injuries (restricted activity, medical treatment, lost time, multiple
injury)
7. Fatality/Serious Disabling Injury
8. Bomb Threat or Terrorist Activity
9. Natural Disaster**
10. Media Event
a. (*Whether immediately controlled or not)
b. (**At the discretion of the management)
B. Incident Report. The initial step in the formal investigation shall be to complete
the Incident Report relative to the type of incident as soon as possible after the
incident. Routing of the report shall be as set forth on the form. A copy of the
Incident Report shall become part of the Incident Investigation Report.
C. Formation of Investigation Teams
D. After receiving initial report the appropriate Division Manager will determine if
a formal investigation is warranted or if an informal investigation will be
appropriate. An investigation team will be formed by the division manager as
outlined below:

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Formal investigation team members and responsibilities:
1. Division Manager Responsible for conducting post investigation
meeting with the investigation team as well as reporting the finding to the
EHS Steering Team.
2. Department/Operations Manager Responsible for assembling the
investigation team, monitoring the progress of the investigation,
participating in the development of the final report and closing meeting.
3. Project Manager Responsible for leading the investigation team and will
assume the title of Team Leader.
4. On-Site Supervisor Responsible for preserving the incident scene. Will
assist in the investigation as a team member.
5. EHS Department Responsible for assisting the investigative team with
interviews, field visits, report development and closing meetings.
6. Team Members at Large Responsible for assisting with any phase of the
investigation as directed by the Operations Manager. This individual may
be chosen for expertise in a certain area.
7. Legal Counsel Responsible for review of the final report.
IV. Conducting the For mal Investigation
The responsibility of the Formal Investigation Team is to determine the obvious and/or
underlying causes of the incident. It is not to assign blame or make judgmental
conclusions. The formal investigation should be a thorough and conscientious
examination of all information, which can be gathered concerning the incident, and not
merely be a repetition of the employees explanation of the incident. In most cases, the
investigation will be in the form of a Root Cause Analysis. Other investigative models
may be used with approval.
All involved personnel (whether employed by company or not) should be
interviewed individually, in person if possible, in the presence of the Formal
Investigation Team Members, if practicable. The interview shall be lead by the
team leader (or a member of the team designated by the team leader) and
conducted, if possible, in the presence of the team in private. The purpose of the
investigation should be stressed to each person interviewed to accurately
determine the circumstances surrounding the incident and to prevent a
recurrence. Interviews may be conducted over the telephone if necessary. Each
team member not present during the interview is to be informed about the results
of any interview. If an interview can not be arranged, a written statement from
each person must be requested. See EHS-P-322a Witness Statement Form.

83
Be polite and courteous during the interview. Take complete notes of what each
person says. Use only open questions. Repeat each response given to be sure that
the information was clearly understood. Close the interview on a positive note.
See EHS-P-322 Incident Investigation Guidance.

A. After the interview of each witness, write an interview summary for each person
interviewed. Report what the person said in the interview using as many of the
interviewed persons words as possible. Do not assume or conclude anything.
This summary will become part of the Incident Investigation Report. Any notes
taken during the interview, no matter how rough or unorganized, must be
marked as Interview Notes and attached to the final report. Interview notes
will not become part of the written Incident Investigation Report. Do not make
any personal copies of the interview notes or interview summaries.
B. If practical, the investigation team should visit the incident site; in any case, at
least one member of the team must visit the site. Locate, mark and securely store
(when appropriate and feasible) any physical evidence, which may be lost,
moved or destroyed at the incident site. The site should be photographed and/or
videotaped. If a video camera is used, do not make editorial comments during
the taping; only describe the site and equipment as it is being taped.
C. Make drawings of the site, which might help someone reading the Incident
Investigation Report to locate all equipment and personnel at the time the
incident occurred. Do not make guesses or assumptions.
D. Writing the Formal Incident Investigation Report. After all witnesses have been
interviewed, the site has been visited and all photographing and videotaping
finished, the investigation team shall prepare a formal report using the Incident
Investigation Report. Additional pages may be attached as needed. Spill or
release investigation reports should clearly indicate probable causes. A copy of
the Incident Report and all videotapes, photographs, sketches and witness
statements must be included in the Incident Investigation Report. The team
leader is responsible for ensuring the Incident Investigation Report is complete
and accurate. Only one copy of this report will be produced. All supporting
materials must be attached. The final report will be delivered under confidential
cover to the Investigation Chief/Division Manager.
V. Post Incident Repor t
A. The division manager must conduct a formal post incident review of all
investigated incidents. This high-level review will include:
1. Investigation Team Leader
2. Operations or Department Manager
3. EHS Department Representative
84
4. Site Supervisor
5. Injured Party etc.
B. At the completion of review, the report findings will be used to develop safety
measures to prevent reoccurrence.
VI. Request for Infor mation
A. Company considers all notes, records, drawings, photographs, video tapes, RCA,
reports and physical evidence of every Incident, Incident Report and Incident
Investigation Report to be confidential and privileged. No company employee
shall discuss or reveal any information about an incident, investigation or any
report generated as a result of the incident with any person who is not an
employee or authorized representative of company. Any requests for information
or for the identity of witnesses shall be immediately referred to the company
Legal Department.
The completed Incident Report can be made available to the client representative
at the work location upon his/her request. This is after all reviews and signing of
the incident report is complete. Requests for additional information must be
referred to the company legal department.

All requests for information from the media (newspapers, television and radio)
shall be referred to the company Legal Department.

VII. Responsibility
Managers and Supervisors are responsible for assuring that all job-related
incidents and injuries are reported immediately and properly documented. The
on-site Cal Dive Supervisor is responsible for notifying company management
and leading the investigation.

Every employee is responsible for immediately reporting any injury, illness


and/or incident, no matter how slight and any unsafe conditions and practices, to
their supervisor. All personnel are responsible for cooperating with
investigations.

Subcontractors/third party personnel are to promptly report any injury, illness


and/or incident, no matter how slight and any unsafe conditions and practices to
their supervisor and the Cal Dive on-site leadership. All personnel are
responsible for cooperating with investigations.

85
VIII. Refer ence
A. Incident Reporting Matrix
B. Incident/Injury Responsibility Flow

INCIDENT REPORTING MATRIX (reference A)


Actual or Potential When to How to Report Follow-up Report to
Severity Report
High CEO and SLT
Medivac (LTI), First by phone Project Manager
fatality, property to EHS On- General Superintendent
damage > $100K, Call, then Port Engineer
spill over 100bbl PMs and EHS (Safety)
Medium PEs; follow
Immediately up with report Department VP
Recordable injury,
as per Project Manager
property damage
distribution list General Superintendent
between $5K to
on the incident Port Engineer
$100K, spill
report within EHS (Safety)
between 1-100 bbl
Low 24 hours Project Manager
First aid, property General Superintendent
damage < $5K, spill Port Engineer
of < 1 bbl EHS (Safety)

86
B. Incident/Injury Responsibility Flow

Incident

Personnel Injury/ NO
Illness or Spill

Facility YES Facility Manager


YES

NO

On-Call EHS
Project Related YES Project Manager
Representative

NO

Port Engineer or
Vessel/Barge YES General
Supertendent

Offshore
Medical Care Medical and/or Resources and/or
Facilities Diving Human
Consultant Resources

Service firms, as
Authorities, as required
VP EHS
required Claims
USCG Service
OSHA Ambulance
MMS (Air or Land)
EPA Spill Control
Fire

87
EHS Standard #13 Permit to Work

Pur pose
The objective of the Permit to Work (PTW) system is to ensure that due
consideration is given to the hazards associated with a particular job/task, and
that the risks are minimized prior to the start of the work, by the implementation
of appropriate control measures. A permit is a communications tool and
checklist, that a hazardous task have been evaluated, hazards identified, risks
minimized, personnel prepared, equipment readied, and anyone who could be
effected by the work is notified, thereby reducing the risk and eliminating injury
to people, damage to assets, and harm to the environment.
Definitions
Permit User: The person(s) carrying out the work and who are under
the control of the person in charge.

Person in Charge: The person responsible for supervising the permit user
and is accountable for completion of the work. He/she
must be at the work-site at all times.

Designated Authorized Person: The person who


manages the work-site permit system and has the
authority to issue a PTW (usually appointed by the
Master/Captain, Superintendent, Facility Manager, or
Job Supervisor). The Master/Captain, Superintendent,
or Facility Manager will be held accountable for
compliance with PTW requirements
Pr ocedur e
I. Per mit to Wor k
The Permit to Work form authorizes personnel to carry out specific work within
certain time and operational constraints. Additionally, it determines which controls are
required to complete the job/task safely.
A. The PTW is valid:
1. For a maximum 12 hours, after which time it must be revalidated.
2. For a specific site.
3. Until the scope of work changes
4. Until an unforeseen hazard arises i.e. weather, injury, etc.

88
II. Typical tasks that shall be contr olled by the PTW system ar e:
A. Hot work, welding, burning, grinding and dealing with explosives etc. (i.e. all
work that can lead to a spark).
B. Breaking into lines that may have the potential to contain residual pressure or
combustible liquids.
C. Isolating electrical or mechanical machinery to permit maintenance or repair.
D. Working at a height of 6 ft. or greater and not protected by guardrails.
E. Removing of Safety Systems (machinery guards, over-rides, limit-switches, etc).
F. Entering confined spaces or where atmosphere is suspect.
G. Underwater burning and welding.
H. Offshore Personnel Transfer by Basket or Swing-rope
I. Diving Vessel LOTO
III. Other per mits r equir ed.
A. The Permit to Work System is comprised of permits from other Standards (i.e.
Lock Out/Tag Out, Fire and Safe work, Confined Space, Working at Height,
Blinding, Subsea burning & welding). Other forms may be filled out in
conjunction with the PTW System (i.e. Hazard Identification Risk Assessments,
HAZCOM and NORM logs etc).
B. Note: Persons working for the Company may occasionally have to operate under
a customers PTW while working on their work-site (i.e. offshore platform).
IV. Per mit to wor k pr ocedur es.
A. The following steps show the procedure for filling out a PTW
1. The Supervisor and Person in Charge, initiates the PTW.
2. Attach Hazard Identification Risk Assessment and or Toolbox/JSA.
3. Ensure that the site is safe and suitable for the work being proposed.
4. Ensure no conflict with other work being done.
5. Review Lock Out/Tag Out Standard, attach permit if required.
6. Review Fire and Safe Work Standard, attach permit if required.
7. Review Blinding Standard, attach log if required.
8. Review Working at Height Standard, attach permit if required.
9. Review Confined Space Standard, attach permit if required.
10. Review Underwater Burning and Standard, attach permit if required.
11. Review all pertinent company Standards.
12. Insure proper PPE is on hand i.e. fall protection, respiratory protection.
13. Supervisor and designated individuals will sign all the required
forms/permits.
89
14. Display all the permits with attachments in area designated by the Captain
or Job Supervisor.
15. The Designated Authorized Person will communicate that work can
commence.
16. At the end of Job/Task turn in a copy of all forms/permits with job
paperwork.
V. Tr aining
Training shall be conducted for Project Managers, Superintendents, Supervisors,
Vessel Master/Captains and Crewmember in Supervisory positions.
VI. Responsibility
A. Supervisor/ Site Manager, IE. Designated Authorized Person
B. Person in Charge
VIII. Refer ence
Not included in this manual:
A. Confined Space Entry Permit.
B. Lock Out Tag out Permit.
C. Working At Height Permit.
D. Fire and Safe work Permit.
E. Underwater Burning/Welding Permit.
F. Lock Out Tag Out Log.
G. Blind List Log.
H. Confined Space Entry Log.
I. Offshore Personnel Transfer

90
EHS Standard #14 Management of Change
Pur pose
To establish a process to follow ensuring changes are identified and managed safely. To
ensure these changes are reviewed at the appropriate level of authority prior to
implementation and properly documented. See EHS-P-348 Management of Change.
Definitions
Change: Any permanent or temporary modification to
procedures, job scope, environmental conditions,
personnel, facilities, or any deviation outside the
documented safe operating limits or procedures.

Risk: The likelihood that a specified hazard will be realized


as a function of the probability of its occurrence and
severity of the consequences

Site Instruction: Within the context of this procedure, any instruction


from a Customer to change or deviate from the planned
work. Such instructions must always be obtained in
writing and may include, without limitation, site query
forms, deviation requests or any other form of
variation request.

Replacement In Kind: Any replacement, repair, or part that satisfies all the
original operational design specifications.
Site Supervisor The senior most site manager responsible for the on-site
implementation of an approved change.

Pr ocedur e
I. Gener al
Managing change means managing risk and the Risk Assessment is the primary tool to
be utilized in managing the risks arising from changes.
Managers and Supervisors are responsible for ensuring that suitable Risk Assessments
are carried out when managing changes within their area of responsibility. The goal of
the Risk Assessment is to bring together the key personnel who have the right
competencies and relevant experience for the purpose of discussing, collecting and

91
assessing concerns, ideas, and operational inputs which will reduce risks and ensure the
safe and effective execution of the change(s) or task(s) under consideration.
The Superintendent/Supervisor along with the Project/Department Manager shall, if
within their range of competence and/or authority, carry out an assessment of both the
change and the associated risk to allocate correct categorization. As a minimum, they
shall discuss the change proposed and agree to the preliminary assessment of the risk
(Low, Medium, or High). The Superintendent/Supervisor is responsible for defining
the change (i.e.: what is the change and what are the reasons for it?) along with input
from any additional personnel or departments as appropriate. See EHS-F-348.

II. Identify the Need for Change


A. It is impossible to precisely define all of the change variables in Company
activities which may give rise to risk. The purpose of this section is to set out the
philosophy and key elements of the process of managing change for
knowledge and understanding.
B. A need for change can result from a variety of situations and it is not within the
scope of this standard to identify all of them. A non-exhaustive list is given
below:
1. Deviation from approved construction procedures
2. Deviation from Standard procedures (e.g. Dive Management System,
MMS, EHS Mgt. System, etc.)
3. Unplanned modifications to vessels and equipment
4. Changes to sequence of offshore operations
5. Deviation from specified safe working practice or work instructions
6. Using an existing piece of equipment for a new task
7. Changes to personnel holding critical competencies
8. Vessel change/substitution
9. Change instigated and/or requested by Customer (Site query, Variation
request, Field change order, etc.)
C. When a change has been identified, before any Risk Assessment is carried out,
the intent shall be communicated to your immediate supervisor.
III. Levels of Change
A. It is the responsibility of the supervisor (Dive Supervisor, Superintendent, Barge
Superintendent in conjunction with the vessel Captain where it impacts the
vessel) to access the level of change in conjunction with the Project Manager.

B. Refer to EHS Standard # 11 (See Hazard Identification and Risk Assessment in


this handbook) and EHS-P-301B to determine the level of risk associated with a
particular change as well as the Criticality of the change. Therefore;

92
Low Risk = Minor Change
Medium Risk = Major Change
High Risk = Critical Change
1. Minor Changes are within the scope of normal operations and are covered
by Basic Operating Procedures or JSAs, standards, policies, and
generic risk assessments. Work task is well within the capability
and competence of the people at the site. Minor changes shall
require approval of immediate supervisor and do not require
completion of the management of change form.

2. Major Changes deviate from the scope of work or standards, procedures


and assessments. The assessment of the work task is deemed to be
within the capability of people and equipment at the site. Major
changes require an approved management of change form. See
EHS-F-348.

3. Critical Changes require further assessment by offshore and onshore project


personnel. Critical changes require an approved management of
change form. See EHS-F-348.

4. Specified Critical Tasks


a. Regardless of the risk assessment outcome, the following criteria
will always be treated as Critical changes requiring a MOC form
and senior management approvals prior to proceeding:

i The change could affect the technical integrity of 3rd party


products (e.g. an interface issue, in which case it must be
formally approved by the relevant 3rd party supplier.
ii Structural modification to installation aids which involve
significant changes in loading, functionality or intended use
iii Alterations to approved commissioning isolation and test
procedures for pressure retaining systems (e.g. manifolds,
trees, pipelines, flow-lines, etc)
iv Impact to statutory or code compliance
v Underwater burning that has not been included in the Project
procedures
IV. Appr ovals for Change
A. All individuals, marked with a check within the box must (where applicable)
approve the change prior to any work going forward. This may include

93
approving job procedures, risk assessments, and/or the Management of Change
Form EHS-F348.

B. Changes are to be authorized in accordance with the following Matrix.

APPROVED
STANDARD COMPANY
CONSTRUCTION CHANGE TO EQUIPMENT
PROCEDURE
PROCEDURE

Critical

Critical

Critical
Minor

Minor

Minor
Major

Major

Major
Offshore

Master
(Where
applicable)
Superintendent
/ Supervisor
(Where
applicable)
Customer
Rep Infor m Infor m Infor m
(Where
applicable)
rd
3 Parties
(Where Infor m Infor m Infor m
applicable)
Critical

Critical

Critical
Minor

Minor

Minor
Major

Major

Major
Onshore

Project
Manager /
General Infor m Infor m Infor m
Manager

Senior
Manager
Infor m Infor m Infor m Infor m Infor m Infor m

V. Managing the Change Process


A. The effective Management of Change (MOC) can range from a Risk Assessment
and JSA at the worksite to a complex process of detailed planning, technical
assessment, consultation, review and approval, involving both onshore and
offshore personnel.
B. However, while it is impractical to define all change variables precisely, it is
essential all associated relevant operations that are directly impacted by any
change are made safe and do not start or continue until the details of this
procedure have been enacted.
C. The level of effort required to successfully manage a change will depend on the
level of risk and complexity. However involved the process becomes, the basic
steps of change management remain the same.

94
D. Recognizing change also means recognizing risk. Risks can arise directly from a
change or indirectly through a more complex chain of cause and effect. In some
cases, small changes may give rise to high levels of risk.
Process of managing changes is provided in the flow chart.

ACTIVITY ACTION RELEVANT FLOW


CHART

DECISION

1- Accessing the level See EHS-F348


of Change

2- Site supervision
accepts need for
change to approved
plan.
3- Does change Verbal approval only.
comply with MINOR Immediate supervisor must
change criteria? approve minor changes.

4- Does change Management of Change


comply with Major Form. Change must be
change criteria? signed by Senior Site
Supervisor, Barge or Ship
Master, Project/Department
Manager, & Client
Representative Offshore as
applicable.

5- Confirm change Management of change


constitutes a Critical form. Change must be
change to approved signed and approved by
plan. Senior Manager, Project
Manager, Barge/Ship
Master, & client onshore
and offshore.

95
VI. Tr aining
A. All employees will be trained in the MOC Standard.
VII. Responsibility
All employees are responsible for understanding the definition of change and
identify such changes as they are proposed so that the change can be managed to
prevent EHS impact.

VIII. Refer ence (not included in this manual)


EHS-F-348Management of Change Form

96
Industr ial Hygiene Awar eness
I. Hydr ocar bon Exposur e (Oil, Condensate, Gas)
Crude oil production contains hydrocarbons of varying toxicity. Skin and respiratory
exposure to the liquids and vapors of these petroleum products should be minimized.
Personnel must take steps to minimize exposure, which may include utilizing PPE.
(Refer to EHS Standards #1, #6 and #7).
II. Bloodbor ne Pathogen Contr ol Plan
A. General Potential exposure to Bloodborne Pathogens such as HIV or Hepatitis
viruses exist in any incident which exposes an employee to blood or body fluids
employees should utilize PPE such as latex gloves, masks or goggles. (Refer to
EHS Standard #1 PPE).
B. Medical First Responders Persons designated to act in a medical response/first-
aid capacity shall be trained in Bloodborne Pathogen Exposure Control and
offered pre-exposure immunizations prior to working in the field. Refer to EHS-
P-325 for other persons identified by the company.
C. Divers Before diving in water contaminated by sewage, divers should be
trained in Bloodborne Pathogen Control Plan and offered pre-exposure
immunizations for Hepatitis A, Hepatitis B, and Tetanus.
III. Hear ing Conser vation
Personnel being exposed to areas identified as hazardous noise areas must wear hearing
protection. These areas are normally identified by posted warning signs. At times, you
may encounter areas where there are no posted signs, but noise hazards may exist. As a
rule of thumb, if you must raise your voice to be heard by another person at a distance
of two feet or less, the noise level is probably above the 85 decibels and requires
hearing protection. (Refer to EHS-P307 and Standard #1 PPE, paragraph III).
IV. Hydr ogen Sulfide
A. H2S may be present at some work sites. H2S is a toxic gas that is normally
colorless, very flammable, soluble in liquids, heavier than air, is corrosive to
metal and, in low concentrations, smells like rotten eggs. See EHS-P-349.
1. H2S can have physical effects ranging from eye irritation to respiratory
arrest. You cannot rely on your sense of smell to alert you to the presence
of H2S since in high concentration it knocks out your smell reflex. If you
detect the smell of rotten eggs or suspect that H2S may be present, you
should leave the work area and move upwind from the smell.
2. If H2S has been present, do not go into any low or confined space until
the spaces have been checked with a H2S gas meter and a competent
person has permitted the space for entry. (Refer to S & E Standard #5

97
Permit Required Confined Space).
3. Any atmosphere that contains > 10 PPM H2S requires that personnel wear
an approved SCBA or breathing system. (Refer to EHS-P-337 and
Standard #7 Respiratory Protection).
V. Abr asive / Sandblasting Oper ations (Silica)
Sandblasting operations create the opportunity for exposure to Silica and other media.
Sandblasting requires the use of a supplied air (positive pressure) sandblasting helmet
with a nozzle brake valve assembly. All other personnel in the area of sandblasting
work shall wear appropriate respirators and eye protection and shall avoid direct
involvement with the sand dust. See EHS-P-338. (Also refer to EHS Standards #1 PPE
and #7 Respiratory Protection).
VI. Cor r osion Pr evention Chemicals
Corrosion prevention chemicals are commonly used in the production of hydrocarbons
to protect valves and piping against rust and corrosion. Exposure to these types of
chemicals should be expected any time a worker is exposed to crude oil, condensate or
natural gas. Proper PPE should be worn in these cases. (Refer to EHS Standards #1, #6
and #8).
VII. Nitr ogen
Nitrogen is a gas at atmospheric conditions and is colorless, odorless, and inert.
Nitrogen is used to displace oxygen in piping and equipment to eliminate the
possibility of explosion or fire. Since nitrogen displaces oxygen, it can cause
suffocation. No one should enter a vessel containing nitrogen until a competent person
approves a confined space permit. (Refer to EHS Standard #5 Permit Required
Confined Space).
VIII. Paint
A. All personnel performing or exposed to paint vapors or spray painting operations
shall wear proper PPE including a respirator. (Refer to EHS Standard #7
Respiratory Protection).
B. All paint waste should be disposed of in accordance with the Waste Management
Plan. Coatings and solvents may be combustible or flammable. Request storage
instruction from your supervisor. (Refer to EHS Standards #1, #7 and #8).

98
IX. Radioactive Mater ials and Equipment (EHS-P-324)
A. Radioactive isotopes and x-ray equipment are widely used throughout the
industry, both onshore and offshore for the non-destructive testing (N.D.T.) of
materials.
B. All persons concerned must appreciate the danger to life, and the injuries, which
can be sustained through the misuse or mishandling of radioactive sources or
materials. It can not be overemphasized that ionizing radiation is a killer unless
precautions are followed and rules obeyed.
C. Radiography is a function carried out by specialized personnel who are approved
and classified under various regulations as required by law.
D. Safety precautions are as follows:
1. At no time should unapproved personnel carry out radiography operations.
2. When in use, barriers must be erected at a safe distance from the
radioactive isotope. No persons other than approved personnel shall cross
these barriers or enter the work area.
3. When working in close proximity to these operations proper PPE shall be
worn as well as a dosimeter. Any suspected contamination of personnel
should be reported to the Person In Charge. (Refer to EHS Standards #1
PPE and #9 NORM and EHS-P-336).
X. Heat Exposure
Heat stress is the bodys inability to handle any combination of high temperatures, high
humidity, and intensive workloads. Heat stress, if not addressed, can lead to heat
exhaustion, heat stroke or possibly even death. This condition can be avoided by
recognizing the signs and symptoms of Heat exposure, consuming plenty of fluids;
taking breaks as necessary to cool down, and being aware of high temperature areas
such as engine rooms.

99
Gener al Safety
I. Manual Lifting
A. Before manual lifting is performed, a job hazard assessment must be completed.
The assessment must consider size, bulk, and weight of the object(s), if
mechanical lifting equipment is required, if two-man lift is required, whether
vision is obscured while carrying and the walking surface and path where the
object is to be carried.

B. All personnel will be trained during initial orientation on the general principles
of ergonomics, recognition of hazards and injuries, procedures for reporting
hazardous conditions, and methods and procedures for early reporting of
injuries. Additionally, job specific training should be given on safe lifting and
work practices, hazards, and controls.

C. Manual lifting equipment such as dollies, hand trucks, lift-assist devices, jacks,
carts, hoists must be used by employees where they can be used without causing
additional risk. Engineering controls such as conveyors, lift tables, and work
station design should be considered when performing a risk assessment or JSA.
Use of provided equipment by employees must be enforced by all supervisors.

D. All injuries caused by improper lifting must be reported on an incident report


form. The on-site supervisor is responsible for investigating each incident. The
company will use investigation findings to develop work procedures and
procedures to prevent future injuries.

E. Where use of lifting equipment is impractical or not possible, two man lifts must
be used. For any lift over 50 Ibs. obtain assistance.

F. Supervisors must periodically evaluate their work areas and employees' work
techniques to assess the potential for and prevention of injuries. New operations,
equipment, procedures, or changes to environmental conditions should be
evaluated to engineer out hazards before work processes are implemented.

II. Chemical Safety


A. When chemicals contact the eye, promptly flush eyes with clean fresh water for
a prolonged period (minimum of 15 minutes) and seek medical attention.
B. In case of skin contact, promptly flush the affected area with water (minimum of
15 minutes), remove contaminated clothing and seek medical attention.
C. Do not smell or taste chemicals; do not eat, drink, smoke, chew gum or apply
cosmetics when in direct contact with chemicals. Wash hands before and after
conducting these activities. (Refer to EHS Standard #6 Hazard Communication).
100
D. Chemicals and equipment shall be properly labeled and stored. No industrial
containers shall be accepted without proper labeling and a MSDS. A MSDS for
each chemical stored on a company property shall be readily available. (Refer to
EHS Standard #6 Hazard Communication).
E. Assure that all persons, including visitors, wear appropriate PPE such as eye
protection, gloves and apron as needed where chemicals are stored or handled.
(Refer to EHS Standards #1 PPE and #6 Hazard Communication).
F. Use appropriate respiratory equipment when air contaminant concentrations are
not sufficiently restricted by engineering controls. (Refer to EHS Standard #7
Respiratory Protection).
G. Indoor storage of flammable and combustible materials shall be in approved
metal cabinets. (Refer to EHS Standard #6 Hazard Communication).
H. Chemical disposal shall be performed as outlined in the areas Waste
Management Plan. (Refer to EHS Standard #8 Solid Waste Management).
I. All chemical spills shall be reported to the immediate supervisor and to the
Environment Health & Safety Department in accordance with the reporting
guideline in this handbook. Technical assistance for cleanup should be obtained.
J. Chemical storage should be minimized. Storage on bench tops or at high levels
is not recommended. Stored chemicals shall be examined periodically for
container integrity. (Refer to EHS Standard #6 Hazard Communication).
K. When an employee transfers a chemical to a portable container, which is
intended for use only during that employees work shift, a hazard
communication label is not required, but is highly recommended. The container
must r emain under the contr ol of the employee who made the tr ansfer and
the pr oduct content must be identified on the container .
III. Compressed Gas Cylinders
A. The industrial gases referred to below can be divided into three categories:
Combustible Non-Combustible Oxidant
Acetylene Nitrogen Oxygen
Hydrogen Helium Nitrous Oxide

B. The color-coding systems for gas cylinders are as follows:


Media US System Color IMCA System Colour
Oxygen Green White
Acetylene Black Maroon

101
Nitrogen Grey W/Black Neck
Helium Grey W/Buff Neck Brown
Mixed Gas Heliox Brown/White
Air Black/White
Argon Dark Blue

C. In addition to color-coding, the name of the product, its chemical formula or


symbol and its hazardous properties should be visible on the cylinder. (Refer to
EHS Standard #6 Hazard Communication).
IV. Gas Cylinder Use, Stor age and Handling
A. Gas cylinder storage and handling must be clear of all sources of ignition.
B. The area must be well-vented, preferably open air, with protection from the
environment.
C. Cylinders should be stored away from corrosive chemicals.
D. Fuel gas and oxygen cylinders, whether they are full or empty, must be
segregated by at least 20 feet or by a non-combustible barrier at least five (5)
feet high. Flammable materials must not be stored within 35 feet of hot work
areas.
E. Fuel gas cylinders (acetylene) must always be stored vertically.
F. Non-fuel cylinders can be stored horizontally in an approved rack.
G. Never use oil or grease as a lubricant on valves or attachments to oxygen
cylinders.
H. Never pick up a cylinder by its protective cap.
V. Cr ane Oper ations (EHS-P-328)
A. Only the following personnel shall operate cranes:
1. Qualified crane operators.
2. Trainees only under direct supervision of a qualified operator.
3. Crane maintenance personnel and inspectors, when necessary, in the
performance of their duties.
B. All persons on site during crane operations shall be instructed in the work to be
performed.
C. A qualified signal person shall be designated. Industry standard hand signals
shall be used.
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D. Tag lines shall be used on all lifts when practical.
E. Slings, fittings and shackles shall be inspected prior to use.
F. Crane loads are not to be lifted or swung overhead of personnel or ships below.
G. A load-rating chart will be located near the crane controls.
H. Weights of all cargo for load line lifts shall be known, prior to making a lift.
VI. Cr ane Inspections
A. Cranes will be inspected daily by the operator and any defects will be reported
and repaired before the crane may be operated. The operator performing the
daily inspection shall ensure that the crane has:
1. Posted load limits and boom angle indicator charts in clear view of the
operator.
2. Safety latching device on all hooks.
3. Emergency shutdown devices.
4. At least five (5) feet of boom tip, block and headache ball painted with
high visibility paint. (Crane hooks should not be painted.)
B. Rigging Practices
1. Use accepted techniques for rigging.
2. Avoid sharp bends in slings. Protect slings from sharp edges and
abrasions.
3. Set loads on proper blocking, never directly on sling.
4. Do not side load.
5. Maintain an angle between the sling and the horizontal greater than forty-
five (45) to reduce stress on slings.
6. Do not work, stand, or walk under suspended loads.
7. Do not leave loads unattended at any time.
8. Tag lines without knots shall be used on all lifts when practical.
9. Tag lines shall not be wrapped around body parts.
10. Rig off a load bearing structural member. Rigging from process
piping/handrails etc. is prohibited.
11. Shackles and other connecting devices shall be completely closed/bolted.
12. Rigging diagrams can be found in the back sections of this handbook.

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C. Slings and Lifting Gear
1. All slings and lifting gear shall be of the approved type.
2. Before use, the equipment shall be checked to ensure that it is in good
condition and not damaged in any way. All vessels lifting gear deemed as
unsafe shall be destroyed.
3. Slings attached to lifting gear that have been shortened or joined together
by knotting shall not be used.
4. Only shackles fitted with the correct pins shall be used; loose bolts, etc.
are not acceptable.
D. Wire Ropes and Connectors
1. Wire rope used in lifting gear shall be examined for worn spots, broken
wires or other weaknesses. It is unsafe to use any crushed wire rope, any
wire rope with several broken wires in close proximity or of which a worn
with spot has undergone a 25% reduction in thickness of the outer wires.
2. Twisting or kinking of wire rope should be avoided as this seriously
affects working life.
3. Wire rope shall be handled by passing it from hand to hand; it should not
be allowed to slide through the hands.
E. Chains
1. A worn or corroded chain, or one that is excessively pitted, shall never be
used.
2. Chains should be checked for distortion of links, rings or hooks.
3. Chain repairs should not be carried out.
4. A chain shall:
Never be hammered to straighten a link.
Never be joined by a nut and bolt.
Never be shortened by twisting and knotting.
Not be subjected to strain if it is in a kinked or twisted position, or if the
links do not move freely.
Not be used for lifting
F. Flat Belt Slings
1. Slings made from woven materials should be regularly checked for cuts,
excessive wear and fraying.

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2. Flat belt slings should be protected from sharp-edge loads by sacking or
similar padding. It is most important that all lifts should take place
vertically since any side pull tends to overload the edge of the belt and
risks tearing it. It also tends to move the belt inwards over possible rough
edges and risks cutting it.
G. Shackles
1. Shackles are widely used for making connections in slinging. They should
be matched to the rigging in use.
2. The shackle pin is a separate part of the shackle but belongs to it. Only the
correct pin should be used.
H. Hooks
1. It is required that every hook used for raising or lowering, or as a means
of suspension, shall be provided with an effective device to prevent the
displacement of the sling or load from the hook.
2. A load can become displaced by the hook falling back when the load is at
rest, particularly in the case of multi-leg slings
VII. Electr ical Safety
A. Only qualified and trained personnel should repair or install electrical equipment
or work around live electrical circuits.
B. Consider all electrical conductors energized.
C. Employees authorized to work on electrical circuits should be trained in CPR
and First Aid.
D. De-energize all circuits before beginning work to prevent the electrical circuits
from being inadvertently energized (EHS Standard #3 Lock Out/ Tag Out).
E. Use suitable protective equipment including rubber gloves, mats and blankets to
provide insulation from other elements, which are energized or grounded.
F. Personnel shall not wear rings, watches or other similar metallic objects while
working on energized electrical equipment.
G. Do not render electrical safety switches inoperative by removal, modification or
destruction.
H. Blown fuses shall be replaced only with the proper type and rating.
I. Use non-conductive ladders when working on or near electrical equipment or
conductors. The use of metal ladders is prohibited. (Refer to General Safety,
Paragraph XVI).
J. Never use defective electrical equipment or extension cords. A periodic
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inspection should be made of all extension cords in stock. Never use a cord that
has been taped up or repaired. Report all defective electrical equipment to your
supervisor.
K. Any person who is not electrically qualified must maintain a minimum distance
of ten feet (10) from any exposed live part.
L. Ground Faults Circuit Interrupters (GFCI)
1. All 120-volt single-phase, 15- and 20-ampere receptacles on work sites,
which are not part of the permanent wiring of the building of structure and
which are in use by employees, shall have approved ground-fault circuit
interrupters for personnel protection.
2. Receptacles on a two-wire, single-phase portable or vehicle mounted
generator rated not more than 5kW, where the circuit conductors of the
generator are insulated from the generator frame and all the grounded
surfaces, need not be protected with GFCI.
M. On ships and marine vessels GFCIs may not work as designed, the following
practices are recommended:
1. Use only double-insulted, U.L. Approved electrical power tools or battery
powered tools.
2. Prior to use, inspect the tool for damage any compromised insulation on
the power cord or plug. Red-tag and remove from service any
questionable equipment.
3. If the ship is dockside and the electrical power supplied to the work site
from the dock (shore power) via an extension cord, then a proper-sized
GFCI must be used.
4. If in doubt contact the ship / barge engineer or port engineer.
VIII. Power Lines
A. All power lines should be considered energized unless proper measures have
been taken for de-energizing. When work is being performed near energized
overhead power lines, any part of the crane, boom, mast, gin poles or machinery
should not be permitted within 10 feet of the power lines rated 50 KV or below.
(Refer to EHS Standard #3 Lock Out/ Tag Out).
B. For energized lines rated above 50 KV, the minimum distance between power
lines and the boom, mast, crane or its load never less than 20 feet unless the
power line is de-energized.

IX. Fir e Pr otection

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A. Response Procedures
1. In case of fire, the following procedure should be used:
a. SUMMON HELP
b. Do not fight a fire before alerting someone else.
c. Analyze the situation, considering:
i Is it a threat to life?
ii Is there damage to public property?
iii Is evacuating or extinguishing the fire possible?
iv Is notification and assistance from outside authorities
appropriate?
v Are hazardous or toxic chemicals present?
d. Isolate all fuel sources and/or threatened facilities.
e. Fighting a fire in the initial stages is considered incipient fire
fighting. DO NOT FIGHT FIRES BEYOND THE INCIPIENT
STAGE UNLESS YOU ARE TRAINED AND EQUIPPED TO DO
SO AS A PART OF A FIRE BRIGADE OR EMERGENCY
RESPONSE TEAM.
f. Locate the firefighting equipment and approach the fire FROM
THE UPWIND SIDE.
g. NEVER OPERATE AN EXTINGUISHER WHEN ANY PART
OF THE BODY IS DIRECTLY IN FRONT OF THE FILL CAP.
h. After the fire is extinguished, stand by to ensure no flashbacks.
i. Assess the damage and complete the necessary documentation. Do
not discuss the fire with anyone other than your supervisor or the
local safety representative. If necessary, someone will be
specifically assigned to relate the facts of the incident to the news
media.
X. Fir e Pr evention Guidelines
A. Prevention is the best fire protection measure.
1. Buildings where solvents or chemicals are handled must be kept well
ventilated at all times.
2. Repair all hydrocarbon liquid or fuel leaks immediately. If immediate
repairs are not possible, post an adequate warning sign, isolate the area
and take extra precautions against fire.
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3. In the event of a hydrocarbon liquid or fuel leak, remove sources of
ignition, such as pilot lights. Report the leak promptly to the supervisor in
charge. Shut off fuel supply or process if possible.
4. Use soapsuds when testing for gas leaks on connections. Never use an
open flame.
5. Use gasoline as a motor fuel only. Using gasoline as a cleaning agent on
company property is strictly forbidden. A high flash point (140 + F)
safety solvent or citrus-based cleaner should be used to clean tools,
machinery and other similar equipment. Wear gloves made of
hydrocarbon-resistant rubber to protect hands.
6. Transport gasoline only in approved, clearly marked containers. Never
place gasoline containers inside car or truck passenger compartments.
7. Properly maintain flame arrestors and keep inspection port covers in
place.
8. When transferring hydrocarbon (especially flushing liquids) from a line
or vessel to another container, the source container and the receiving
container should be electrically bonded and grounded to prevent ignition
due to static electricity.
XI. Fir e Extinguisher Inspection and Maintenance
A. Fire extinguishers are an important segment of any fire protection program. Fire
extinguishers should be:
1. Accessible
2. Properly maintained
3. Inspected monthly by trained personnel and documented
4. Hydro-statically tested as required.
B. The supervisor is responsible for ensuring that all extinguishers are properly
maintained and inspected. Each employee should know how to identify and
report extinguishers needing recharging and/or maintenance.
XII. Welding and Bur ning (EHS-P-350)
A. Before striking an arc or lighting a torch, refer to EHS Standard #2 Fire and Hot
Work. All hot work outside of a designated hot work area requires a hot work
permit.
B. Keep welding leads and burning hoses clear of passageways.
C. Inspect all leads, ground clamps, welding machines, hose gauges and cylinders
each day before use.

108
D. Be sure all fittings and couplings are tight.
E. If bottles are be moved they must be protected from falling. Bottles should be
stored in a secured upright position with valve stems protected.
F. Inline check valves are to be installed in the oxygen and acetylene hoses
between the bottle regulator and the torch or heating device head.
G. Avoid breathing fumes. Use exhaust systems or blower fans to remove fumes in
confined spaces. Use a respirator when necessary. (Refer to EHS Standard #7
Respiratory Protection).
H. No welding or burning is to be done on a closed vessel or tank unless it has been
decontaminated and is gas free. (Refer to EHS Standard #2 Fire and Hot Work).
I. Each welder/burner is responsible for containing spark and slag and removing
combustible materials form the work area. They shall keep hoses and leads clear
of sparks and hot slag.
J. Ground leads should be grounded as close to the work site as possible, but
normally not more than 15 feet from the work site. An appropriate fire
extinguisher shall be within 25 feet of the work site. A fire watch will be
assigned to any welding or cutting operation performed outside the designated
hot work area. A fire watch shall be assigned no other duties while hot work is
being conducted. If burning or welding is being performed on a bulkhead or
deck, then a second fire watch must be assigned to watch the space opposite
(inside wall) the side that burning/welding is being done.
K. A fire watch shall not leave the hot work site without being properly replaced.
The fire watch shall remain at the hot work site for at least 30 minutes after the
hot work has been completed.
L. First aid equipment will be available at all times while welding and burning.
XIII. For klift Oper ation
A. Forklift Operator Training
1. Operators are required to certify competency on all types of equipment.
2. Operators are required to have formal instruction which may include
lecture, discussion, interactive computer learning, videos, and/or written
materials. Operators are required to have practical training which involves
instructor demonstrations and trainee exercises. Operator evaluation -
critiques are required.
3. All trainers must have the knowledge and ability to teach and evaluate
operators, training will be documented by the training department.
4. Training will include the topics identified in OSHA, 1910.178 (l)(3)
5. Training certificates will be issued and will include:
a. operators name,

109
b. training date,
c. evaluation date, and
d. trainer/evaluator name.
6. Recertification is required every 3 years. Mandatory refresher training is
required if an operator demonstrates unsafe operations, has an accident, is
assigned to a different vehicle type, or if there are changes in conditions
where the forklift is being operated.
B. The operator shall be responsible for inspecting the forklift before beginning
operation. The inspection as a minimum should include:
1. All fluid levels.
2. Brakes and hydraulics.
3. Lights and warning devices.
4. Safety equipment, IE. seat belts, fire extinguisher, etc.
a. If any deficiencies are identified, report them to your supervisor and
do not use the forklift.
C. Only handle loads that are within the rated capacity of the forklift being used.
D. Never allow passengers to ride on the forklift.
E. Always use personal restraint belts.
F. Carry all loads as low as possible; the forks should be 6 to 12 inches off the
ground.
G. When a load blocks the operators view, the forklift may be operated in reverse.
A signalman shall be used when the load impairs the operators view.
H. Do not use the forks to lift personnel from overhead without an approved
platform.
I. When left unattended the forklift should be turned off, the forks lowered to the
ground and the brake set.
J. The safe working load (SWL) should be clearly marked in a conspicuous place
on the forklift.
K. If the forklift is being used to load from a loading dock to the inside of a trailer,
the operator must verify trailer chocks, supports, and dock plates prior to
loading/unloading.

XIV. Office Safety


A. Protection from Fire
110
1. Be familiar with fire notification procedures.
2. Be familiar with emergency procedures and know the appropriate
evacuation route for your work location.
a. If you leave your work location for a fire or fire drill close all
doors behind you.
b. Never use an elevator when evacuating a building.
B. Housekeeping
1. Keep all flammable and combustible liquids and gases in appropriate
storage cabinet. (Refer to EHS Standard #6 Hazard Communication).
2. Keep all passageways, entryways, stairways, storerooms, aisle and
workspaces clean, orderly and well maintained with no obstructions.
3. Stack boxes and other materials to prevent them from falling.
4. File drawers and desk drawers should be kept closed when not in use.
5. Do not open more than one upper file drawer at a time. Heavy files should
be kept in the lower file drawers. Do not open a file drawer if someone is
working below them.
6. Keep all chair legs on the floor. Never lean in any position that does not
allow for all chair legs to remain on the floor.
7. Never use a chair for reaching or climbing. Use a ladder or stepstool
designed for climbing or reaching. (Refer to General Safety, Paragraph
XVII Ladders).
8. Keep dive knives, alternative cutting devices, paper cutters and scissors in
the closed position when not in use.
9. When carrying materials, do not overload yourself and use proper lifting
techniques. (Refer to General Safety, Paragraph I Manual Lifting).
10. Get help when needed.
11. Use handrails when going up and down stairs. Never run up or down
stairs.
12. Avoid the use of extension cords as much as possible. If the need exists to
use an extension cord, tape exposed cords to the floor to reduce tripping
hazards.
13. Do not overload power outlets by using multiple outlet extensions.
14. When removing plugs from wall, pull on the plugs and not on the cord.
15. Machines with moving parts, high temperature hazards, and electrical
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shock potential shall not be operated without proper safeguards in place.
XV. Shop and War ehouse
A. Workers must take special precautions when working with cleaning agents, hand
tools, power tools, grinders, wire wheels, air hoses and air guns.
B. Housekeeping
1. Clean up any spills immediately.
2. Keep walkways clear of obstructions.
3. Use containers provided for waste and scrap.
4. Keep your work area clean.
5. Store hazardous and flammable substances in the correct storage area.
XVI. Hoses and Air Guns
Workers should take the following precautions with air hoses and air guns:
Make sure the nozzle pressure does not exceed 30 psig.
Make sure the recommended working pressure is not exceeded. Ideal pressure will
vary with equipment.
Never use oxygen, nitrogen, natural gas or other compressed gases in lieu of
compressed air.
Never use an air gun or compressed air to clean yourself or your clothing.
XVII. Ladder s (EHS-P-327)
A. The structure of fixed, portable and job-made ladders must conform to
government standards for occupational safety.
B. The following guidelines must be ensured when working with ladders:
1. When accessing an upper level, extend the ladder at least three (3) ft.
above the surface.
2. Keep ladders free of oil, grease and other hazards.
3. Do not load a ladder above its intended weight capacity.
4. Use ladders only for their intended purpose.
5. Keep areas at the top and the bottom of ladder clean and clear.
6. Never move, shift or extend ladder when someone is on it.
7. Never use defective ladders. If faulty ladders are discovered, remove them
from service and tag them as Dangerous, Do Not Use. They should be

112
destroyed as soon as possible.
8. Always face the ladder when ascending or descending.
9. When climbing a ladder, never carry an object that may interfere with
balance.
10. Ladders should always have non-skid feet.
XVIII. Cleaning Agents (Refer to EHS Standar ds #1, #6 and #7)
A. When working with cleaning agents workers should take the following
precautions.
1. Refer to the MSDS before using any cleaning agent.
2. Only use approved cleaning agents with a flash point of 140 F or above.
3. Wear gloves and eye protection to prevent skin irritation and eye injury.
Refer to MSDS for the proper PPE.
4. Do not breathe cleaning vapors. Make sure the work area is well
ventilated.
5. Do not clean clothes with flammable liquids.
6. Never use gasoline as a cleaning agent.
7. Take care when mixing chemicals Strong acids and bases can be
combined to make an explosive mixture, and some bleaches and soaps can
combine to make poisonous gas.
8. Do not spray flammable cleaning agents on hot equipment.
9. Avoid repeated or prolonged exposure to cleaning agents, as this could
cause skin irritation. Check the MSDS for the proper PPE.
10. Avoid using cleaning agents that cannot be recycled.
XVIX. Hand Tools
A. Workers should take the following precautions when working with hand tools:
1. Use the right tool for the job.
2. Return all tools to their storage place when not in use.
3. Defective tools should be destroyed and thrown away.
4. Never use a cold chisel with a mushroomed head.
5. Keep tools clean. Remove any oils or grease before storing.

113
XX. Power Tools
A. Never carry a tool by its cord.
B. Never yank the cord to unplug the tool.
C. Keep cords away from heat, liquids and sharp objects.
D. Unplug tools after use and when servicing or replacing parts.
E. Keep both hands free to hold the tool.
F. Remove defective tools from the work or storage area and tag DO NOT USE.
(Refer to EHS Standard #3 Lock Out/ Tag Out).
G. Wear appropriate PPE. (Refer to EHS Standard #1 PPE).
H. Never remove a ground prong from a power cord plug or use an adapter to
nullify the grounding circuit.
I. Never use a power tool in an area where flammable/combustible materials are
present without a current Hot Work Permit. (Refer to EHS Standard #13 Permit
to Work).
XXI. Wir e Wheel and Gr inder s
A. Workers should take extra precautions when working with grinders and wire
wheels.
B. All people in the immediate work area must wear eye protection. In addition,
workers should do the following:
1. Wear eye/face protection and additional PPE as necessary. (Refer to EHS
Standard #1 PPE).
2. Move flammable/combustible materials away from sparks.
3. On a grinder securely clamp the work rest and tongue guard so that they
are no more than 1/16 inch, respectively, from the wheels.
4. Make sure the wheel, shaft hole and motor speeds are all compatible.
XXII. Knife and Cutting Safety
A. The use of knives in the work place is prohibited with the exception of: divers
working in the water, standby divers fully dressed, supervisors on the deck,
medics in an emergency or rescue situation, and galley personnel preparing food.
All other knife use must be authorized in writing.
B. Dive tenders and deck hands will be required to use the alternative cutting tools
identified and distributed by the company. Dive tenders and deck hands
identified using a knife without supervisor approval will be subject to
disciplinary action.
114
C. Do not use knives as a screwdriver, prying device, hammer or saw.
D. If knife use is required, when cutting, stroke away from yourself.
XXIII. Repor ting for Duty
A. All personnel must maintain a high standard of personal hygiene; this will
include good grooming, clean clothes or uniform. The following is not permitted
even for transportation to and from the job site:
1. No open toed shoes.
2. No shorts.
3. No sleeveless shirts or tank tops.
B. The following is required when reporting for work:
1. Health physical examinations must be up to date depending on job
function.
2. Drug and alcohol test must be up to date.
3. You must not be suffering from a communicable disease.
4. You must not be under the influence of alcohol or drugs.
5. You must not suffer from any condition impairing your judgment or
ability to carry out your normal duties.
6. Your certifications and other documents related to your occupation shall
be valid and current.
C. The following non-controlled items are not allowed on a company property or
work site:
1. Alcohol/non-prescribed or illegal drugs.
2. Explosives, fireworks, firearms and highly flammable articles.
3. Poisons
4. Radioactive substances.
5. Other dangerous articles or materials.
XXIV. Tr anspor tation
A. The items identified in this section apply to the operation of all transportation
equipment, including vehicles, aircraft and vessels that are leased, rented or
owned by company offshore.
B. The operator (pilot, captain or driver) of the transport has complete authority
over the operation of his vehicle. The operator must be appropriately licensed

115
and authorized to operate the equipment, and is responsible for the operation of
the equipment and passengers at all times, loading of personnel and materials
and weight distribution of the load.
XXV. Vehicle Safety
A. Only authorized employees with a valid and current license will be allowed to
drive a motor vehicle. Drivers shall not operate a motor vehicle while under the
influence of alcohol, illegal drugs, or prescription or over-the counter
medications that might impair their driving skills Posted speed limits will not be
exceeded. At times driving at the maximum-posted speed limit can be too fast
for safety in some situations. The driver of a company-owned, rented or leased
vehicle shall use good judgment, plan their trip, and proceed at a speed suitable
for the conditions of the vehicle, road, weather, and traffic flow. Drivers will
maintain a safe distance between other vehicles. Drivers will focus on driving
and not be distracted by mobile phones, passenger conversations, manipulating
radios or other equipment while driving.
1. The vehicle shall be fit for the purpose, inspected before each trip, and
shall be maintained in safe working order.
2. Do not drive a vehicle with a door open or other compartment unsecured.
Personnel must not get out of a vehicle when it is in motion.
3. All operators and passengers must use seat belts and shoulder harnesses if
the vehicle is so equipped.
4. Vehicles should be properly parked. When possible, they should be
parked so that no backing is required when leaving, unless doing so
creates a greater hazard.
5. When riding in company provided transportation or third party
chauffeured vehicles, the driver has total authority with regard to smoking
and eating in the vehicle. Drinking alcoholic beverages is prohibited.
6. Loads shall be secure and shall not exceed manufacturers specifications
and legal limits for the vehicle. Trailers being pulled must have safety
chains of sufficient capacity and size to hold the trailer loads in the event
the coupling mechanism fails.
7. Smoking is prohibited near a vehicle being refueled.
8. Authorized drivers will report any collision or traffic violation while
driving on company duties to their supervisor. An incident report must be
completed any time a vehicle is damaged. (Refer to Incident Reporting).

116
XXVI. Helicopter Tr anspor tation
A. The guidelines below must be followed for all helicopter transportation.
1. The pilot has final decision regarding loading of personnel, loading of
cargo, weight distribution of the load and flight operations.
2. Smoking by passengers is prohibited at any time while on or near the
aircraft.
3. Passengers will report at the staging area one hour before scheduled
departure, report their weight and the weight of their luggage.
4. Passengers will participate in the pre-flight briefing provided by the pilot.
5. Passengers will learn the location and proper use of emergency equipment
such as life rafts, emergency equipment kits and fire extinguishers.
6. While in-flight, passengers must never open the doors of the aircraft or
throw anything out of the craft.
7. Never move about the cabin of a helicopter or float plane in flight.
B. Loading and unloading passengers and cargo:
1. Do not approach an aircraft without the pilots knowledge when the rotor
blades are turning. Wait for a signal from the pilot before approaching.
2. Approach and leave a helicopter in a crouched position so that you are
well below the rotating rotor tips. Use caution, as the front portion of
helicopter rotor blades can dip dangerously low and can strike personnel.
3. Always approach and leave the aircraft at a 90 angle from the sides and in
view of the pilot.
4. Never walk near or under the tail boom, tail rotor or approach from the
rear of a helicopter.
5. Passengers must not disembark an aircraft until instructed to do so by the
pilot.
6. Passengers must hand carry hard-hats, caps or other light items that can be
blown into the rotor or engine intake.
7. Hearing protection should be worn during all helicopter flights. (Refer to
EHS Standard #1 PPE).
XXVII. Water Tr anspor tation
A. Transportation by vessel or boat including disembarking is potentially
hazardous. The captain is in charge of the vessel and its passengers. Follow the
captains instructions as to the loading procedures, storage of luggage and cargo,

117
seating arrangements and smoking restrictions.
B. Prior to departing, the captain must ensure that all passengers are briefed in areas
pertinent to their safety while onboard the vessel.
C. Passengers must transfer to and from the ship under the direction of the captain.
Upon arrival in port, crew personnel may not transfer off the vessel until the
captain has given the all clear.
D. Passengers must ride in the cabin unless specific authorization is granted by the
captain for riding in wheelhouse or outside the cabin.
E. In the cabin, no passenger or crewmember may wear open toed shoes i.e. sandals
or flip-flops while climbing or descending stairs.
F. All persons should take special precautions and be careful of hands and fingers
around doors, hatches and hinges.
XXVIII. Tr ansfer by Per sonnel Basket
A. A Personnel Transfer Permit and JSA must be completed prior to basket
transfers
B. Personnel shall wear an Approved Personal Flotation Device, snugly fitted and
securely fastened during personnel transfer.
C. Position yourself on the deck of the boat as directed by the boat crew.
D. Place your luggage in the bottom center of the basket. Only personal articles
should be transferred in a personnel basket.
E. Place one foot on the outside rim of the basket; grasp the basket ropes securely.
Keep your knees slightly bent or flexed.
F. Prepare for unexpected moves, particularly in rough seas.
G. As the basket is lifted off the boat deck, step onto the outside rim of the basket
with the other foot. Do not lean in or out; stand straight up.
XXIX. Tr ansfer by Swing Rope
A. A Personnel Transfer Permit and JSA must be completed prior to swing rope
transfers
B. Personnel shall wear an Approved Personal Flotation Device, snugly fitted and
securely fastened during personnel transfer by swing rope.
C. Face where the vessel is against the platform.
D. Have both hands and arms free.
E. Do not carry luggage while transferring by swing rope.

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F. Catch the knotted rope when the vessel is on top of a swell and swing to the
platform by pushing off the vessel with your feet.
G. Only attempt to transfer when you are comfortable and ready. Do not allow
anyone to direct you when to transfer.
H. Assist others.
I. Never stand on the vessel gunnels to transfer; a platform may need to be built or
erected to properly transfer.
J. When transferring to or from a structure, the landing must be of adequate size
and condition for safe transfer.
XXX. Wor king Alone or in Isolation
A. Whenever reasonably practicable, Cal Dive International will avoid personnel
working alone. However, on occasion, the situation may arise where working
alone is not practicably avoidable. Working alone or in isolation is only allowed
when it can be done safely.
B. Supervisor shall schedule work to minimize the need or potential hazards of
working alone.
C. Employees shall consult with their supervisors as necessary to schedule work
done after hours or in isolation.
D. When working under potentially hazardous circumstances employees are
normally accompanied. The level of proximity required will vary according to
circumstances and the supervisor will need to exercise discretion and shall
perform a risk assessment to help focus on mitigating any reasonably
foreseeable hazards. Potentially hazardous work includes:
1. Moving equipment
2. Work carried out under the PTW system
3. Working with machine shop tools, powered tools and equipment
4. Electrical work
5. Work on high pressure lines and equipment
6. Work involving hazardous/flammable liquids
7. Working in pressure vessels or tankage
8. Working on the decks of vessels especially at night
E. Perform a risk assessment and JSA prior to the start of the task(s) to be
performed. If the employee feels the risks preclude working alone, the employee
will immediately contact his or her supervisor.

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F. Establish a means of communication and schedule contact intervals between the
lone worker and his or her supervisor. This also includes a means of summoning
aid it the need arises.
G. Establish a back up procedure to follow in the event of a communication failure
or the contact intervals are not adhered to. This could include sending another
employee to the site.

Repor ting
This section briefly describes reporting requirements for injuries, incidents and vehicle
collision. Questions regarding incident reporting should be directed to the EHS Department.
I. Company Employee and Subcontr actor Injur ies
All work related injuries (company or subcontractor) shall be immediately reported to
the supervisor on location. Following proper medical treatment, the supervisor shall
ensure a complete the CDI Injury and Illness Report is entered into the system
(electronic report) or otherwise forwarded it to the EHS Department within 24 hours.
The original report with signatures may be scanned and attached to the electronic
report or will be sent to the EHS department in the next mail run. A copy of the report
may be maintained at the work site. (Refer to EHS Standard #12 Incident and Injury
Investigation).
III. Near Miss Incidents
A. A Near Miss is an incident or situation arising out of company operations, which
create a risk to life or property.
B. All Near Miss incidents shall be reported to your supervisor. Supervisors shall
investigate, identify and implement corrective actions, and document all on the
reporting form as a near miss. This form should be entered into the system
(electronic report) or otherwise forwarded to the EHS Department within 24
hours. A copy may be retained at the job site. (Refer to EHS Standard #12
Incident and Injury Investigation).
C. Supervisors shall investigate, identify and implement corrective actions, and
document all on the reporting form. It is possible that the incident may require a
formal investigation. Management will decide this. In these cases, the company
Incident Investigation standard will be followed. (Refer to EHS Standard #12
Incident and Injury Investigation).

IV. Vehicle Collision


All vehicle collisions involving a company vehicle will be reported to your supervisor
immediately. A vehicle collision report will be completed and submitted to the EHS
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Department. Under no circumstances shall an employee admit responsibility or discuss
the incident, except as required by law enforcement officials.
V. Pr oper ty Damage/Business Inter r uption Loss
Property damages or loss should be reported immediately to your supervisor.
Additionally, the following reports should be prepared:
For company property damage or theft within 24 hours of notification, an
initial report of property damage shall be completed on the CDI Incident
report form.
For non-company property damage, within 24 hours, an initial report of
damage will be filed with the CDI claims report.
VI. Spills
A. All chemical spills onshore and offshore shall be reported to the supervisor,
project manager, ships fleet manager and the EHS Department.
B. The spill should be isolated if possible. The EHS Department and the
project/fleet manager will manage the spill clean up.
C. The EHS Department will notify regulatory agencies. In many cases these
agencies must be contacted within one hour of occurrence. A spill report shall be
completed as soon as possible by the supervisor.

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Conver sion Tables/Rigging/Char ts/For mulas
USEFUL DIVING FORMULAS
T FORMULA
The T Formula is a simplified method of working most problems encountered in diving
operations. There are a few simple steps to be remembered, which will shorten the time in
working the problem and give the operator confidence that is needed when working out
diving formulas.
The mechanics of the T formula are that each side of the formula must be made absolute
and deal in atmospheres. As there are three sides to the formula, you will always have two
known factors and one unknown factor. In most diving problems these factors are: depth,
percent of oxygen and partial pressure of oxygen. Depending on what you want to know, you
will have to divide or multiply. All percents must be changed to a decimal form.
Example: 21% = .21
To work the T formula, you must divide the bottom numbers into the top number to
achieve the unknown and you must multiply across the line to achieve the other possible
unknown.
Gener al:
ppX
_______________
ata / .%
Solve for the missing element when the other two are known, where:
ppX = partial pressure of a gas (in tam)
ata = atmospheres absolute
.% = decimal percent of gas
Atmospher es absolute (ata):
ata = depth + 33 or Pressure + 14.
33 14.7
Par tial pr essur e of a gas:
pp(psi) = [ (D + 33) x .445 ] x .% of gas
pp(atm) = [ D + 33 ] x .% of gas
33
pp(fsw) = (D + 33 ) x .% of gas

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Surface equivalent:
S.E. (atm) =. % Of gas at depth X ata
Depth of blow down:
D.O.B.D. = ppO2 ppO2P X 33
.% pres
Where:
ppO2R = partial pressure of O2 required
ppO2P = partial pressure of O2 present
.% pres = decimal percent of O2 in pressurization gas
D.O.B.D. = Depth of Blowdown

Maximum Oxygen percent for a depth:


MO2 = ppO2L x 33 X 100
D + 33
Where:
MO2 = Maximum O2 percent for a depth (decimal percent)
ppO2 L = Limiting partial pressure of oxygen (atm)
D = Depth

Maximum depth for an Oxygen percent


M.D. =ppO2L x 33 -3
O2 %
Where:

M.D. = Maximum permissible depth for a given oxygen percent (feet)


ppO L = Limiting partial pressure of oxygen (atm)
O2% = Percent of oxygen (decimal)

Equations 8 through 13 are useful when mixing gas, and cover the six commonly encountered
mixing situations. In these equations, the following symbols apply:

123
% O2I = initial oxygen percentage expressed as a decimal.
%O2a = oxygen percentage added expressed as a decimal.
%O2f = final oxygen percentage required expressed as a decimal.
%O2m = oxygen percentage added expressed as a decimal.
%HeI = initial helium percentage expressed as a decimal.
%Hea = helium percentage added expressed as a decimal.
%Hef = final helium percentage required expressed as a decimal.
ppO2 = partial pressure of oxygen expressed in psi.
ppHe = partial pressure of helium expressed in psi.
Pi = initial pressure in psi.
Pa = pressure added in psi.
Pf = final pressure in psi.
Pv = pressure vented to in psi.

Cr eate a new mix fr om 100% O2 and 100% He using the equation:


Pa = % O2f x Pf
Known: The % O2 required and the final pressure desired.
Calculate: Pa = % O2f x Pf
Add the calculated psi of oxygen to the cylinder then fill with 100% helium
to the final pressure.

Incr ease the pr essur e of a given mix using 100% O2 and 100% He:
Known: The initial % O2, the initial pressure, the final % O2 required, and the final
pressure desired.
Calculate: Pa = % O2f (Pf Pi)
Add the calculated psi of oxygen to the cylinder then fill with 100% helium to the final
pressure.

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Acronyms

AB Able Body Seaman


ABS American Bureau of Shipping
ADCI Association of Diving Contractor International
BOL Bill of Lading
BOP Basic Operating Philosophy
Bop Blow Out Preventor
BSP Behavioral Safety Process
BT Bottom Time
CAPT Captain
CDI Cal Dive International
CERT Certification
CFR Code of Federal Regulations
CO Company
COL Collision
CP Cathodic Protection
CP (Hose) Chicago Pneumatic
CPR Cardiopulmonary Resuscitation
DA Deep Air
DAP Deep Air Package
DB Derrick Barge
DCS Decompression
DDC Deck Decompression Chamber
DDR Daily Deficiency Report (Marine)
DMR Daily Marine Report
DMT Diver Medical Technician
DOT Department of Transportation
DP Dynamically Positioned
DSV Dive Support Vessel
DSVP Dive Supervisor
DT Diver/Tender
DVR Diver
ED Equipment Damage
EHS Environmental, Health, and Safety
EMT Emergency Medical Technician
EPMR EHS Proactive Monitoring Report
EPR EHS Performance Report

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E/R Enroute
ERT Energy Resource Technology
EXP Explosion
FA First Aid
FR Fire
FRO For Record Only
FSW Feet of Seawater
FTLY Injury caused - Fatality
GM General Manager
GoM Gulf of Mexico
He Helium
HeO2 Helium Oxygen Mixed Gas
HAZMAT Hazardous Materials
HEP Hurricane Evacuation Plan
HP High Pressure
HR Human Resources
HRC Hyperbaric Rescue Capsule
HYD Hydraulic
IFTLY Illness caused - Fatality
ILWC Illness
IMED Illness caused - Medical
IRWC Illness caused - Reassigned Work Condition
JSA Job Safety Analysis
LB Left bottom; Lifeboat; Lay barge
LOG Loss of Gas
LOTO Lock Out / Tag Out
LP Low Pressure
LS Left Surface
LSS Life Support Supervisor
LST Life Support Technician
LT Lead Tender
LWC Lost Work Condition - Injury
LWO Logistics Work Order
MED Injury caused - Medical
MMS Mineral Management System
MOC Management of Change
MPT Multi-purpose Tower
MSDS Material Safety Data Sheet
MT (MPI) Magnetic Particle Inspection
MSV Multi-service Vessel
MV Motor Vessel
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N2O2 Nitrogen Oxygen
NDT Non Destructive Testing
NM Near Miss
NM/ED Near Miss - Equipment Damage
NORM Naturally Occurring Radioactive Material
NWR Non Work Related - Injury
NWRI Non Work Related - Illness
O2 Oxygen
OCS Outer Continental Shelf
OJT On the Job Training
OPS Operations
OQ Operator Qualifications
OR Offshore Resources
OS Ordinary Seaman
OSHA Occupational Safety and Health Administrations
OSV Offshore Supply Vessel
OT Overtime
PAC Personnel in Addition to Crew
PC Project Coordinator
PDE Personal Dive Equipment
PE Port Engineer
PIC Person in Charge
PM Project Manager
POB Persons on Board
POC Point of Contact
POI Port of Iberia
POI Poisoning
POL Pollution
PPE Personal Protective Equipment
PRA Project Risk Assessment
PSI Pounds per Square Inch
PTW Permit to Work
PVHO Pressure Vessel for Human Occupancy
PX Passenger
QA Quality Assurance
QMED Qualified Member of the Engineering Department
QSP Quality System Process
RC Respiratory Condition
RCA Root Cause Analysis
REST Restricted Duty
RFP Request for Proposal
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RFQ Request for Quotation
ROV Remotely-operated Vehicles
RS Reach Surface
RWC Injury caused - Reassigned Work Condition
SA Shallow Air
SAP Shallow Air Package
SAT Saturation Diving
SC Skin Condition
SCM Supply Chain Management
SEC Security and Exchange Commission
SIM OPS Simultaneous Operations
SN Serial Number
SSE Short Service Employee
STBD Starboard
STBY Standby
SUP Supervisor
SUPT Superintendent
TDR Tender
TRIR Total Recordable Incident Rate
TS Topside
TUP Transfer Under Pressure
USCG United States Coast Guard
UT Ultrasonic Inspection
UW Underwater
VEH Vehicular
VP Vice President
VT Visual Inspection
WO Work Order
WOC Waiting on Cement
WOO Waiting on Orders/Operator
WOW Waiting on Weather
WX Weather

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Notes:

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