Date Issued: 08/09/13

Confined Space Entry – Life Saving Rules Directive Document No: 005.08.13
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SCOPE OF CONFINED SPACE ENTRY LIFE SAVING RULES DIRECTIVE:

This Directive on Confined Space Entry has been approved by the CPChem Environmental, Health, Safety
and Security Policy Committee (EHSSPC). The requirements of this Directive shall be incorporated into
each facility’s Confined Space Entry Program. This Directive shall apply to all spaces meeting the definition
of a confined space and permit confined space (“confined space”), as defined by the 29 CFR § 1910.146
U.S. Occupational Safety and Health Administration (OSHA) regulation. Any facility exceptions to this
Directive shall follow the variance process in Global OE Procedure EHS-1110, Development, Revision and
Approval of Global OE Procedures and the OE System Manual.
All CPChem and Affiliate facilities (“Company”) where CPChem is in a position of control, either through
voting control or third-party service operatorship allowing such application, must address the requirements
of this Directive. This Directive and facility Confined Space Programs represent CPChem Policy. Violations
of CPChem Policy may result in disciplinary action, up to and including termination of employment,
consistent with CPChem HR Policy and any applicable facility policies and contracts.
CONFINED SPACE ENTRY REQUIREMENTS:
The requirements of this Directive are based on the following:
A. No entry shall be allowed in spaces where testing results are outside of ranges for oxygen supply or
exceed the limits for flammable and toxic materials referenced below (see Sections 1.2 and 2.1.1):
• Oxygen supply (O2) must be in the range of 19.5% to 23.5%;
• Flammable gas, vapor, or mist concentration of any chemical/mixture must not exceed 10%
of its Lower Explosive Limits (LEL); or
• All confined space entrants and confined space attendants must always be protected
against chemical exposure to levels below applicable Occupational Exposure Limits
(OELs), as identified in CPChem’s Occupational Exposure Limits table located on the
Corporate EHSS Homepage.
B. A Mitigation Plan developed by a cross-functional team of appropriate subject matter experts
(SMEs) and approved by the Facility Manager is required for work in spaces which cannot be
controlled to 0% LEL and below each chemical’s eight hour (8-hr) time weighted average (TWA)
OEL (see Sections 2.1.2 and 4.).
C. Inert Entry is inherently dangerous and shall be performed in accordance with recognized industry
best practices, such as API STD 2217A, Guidelines for Safe Work in Inert Confined Spaces in the
Petroleum and Petrochemical Industries (2009). If unsure about applicability of an industry best
practice, please consult with EHSS for approval of selected practice.
D. A Mitigation Plan developed by a cross-functional team of appropriate SMEs and approved by the
Facility Manager is required for work in inert spaces (see Section 2.2).
E. Personal and continuous monitoring, with alarms, is required in all confined spaces. All confined
space entrants and all confined space attendants shall wear a personal monitor to be aware of
atmospheric hazards (see Section 3.4).
F. A Job Safety Analysis (JSA) is required for every confined space entry due to potentially high
consequences (see Section 3.2).
G. All tools and equipment used in confined spaces must be safe and suitable for the entry conditions
and not create additional hazards (see Section 3.3).
H. A Permitting Authority (see Section 3.5) must personally and physically review all aspects of each
confined space entry where personnel are permitted to enter, to ensure all elements of the confined
space permit are addressed, and the confined space conditions safe, before issuing the permit (see
Section 3.5).
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I. Individuals involved in confined space work activities must be trained and demonstrate competency
(see Sections 5.1 and 5.2).
J. All individuals associated with confined space work activities are empowered and responsible to
STOP WORK if anything does not appear safe, is not fully understood, or is not being performed
per written instructions (i.e., policies, procedures, Mitigation Plans), JSAs, and permits (see
Sections 3.5.3 and 3.5.4).

CONFINED SPACE ENTRY STANDARDS:

1. Prohibited Entries and Pre-Entry Atmospheric Testing
1.1 Pre-entry air monitoring shall be performed before entering a confined space, confirming the
atmospheric concentrations are within an acceptable range for oxygen and lower than prohibited
values for flammable and toxic materials. Any ventilation shall be suspended for at least thirty
minutes before testing the space (including any re-testing). Any pre-entry testing shall include
monitoring for O2, LEL, carbon monoxide (CO), and hydrogen sulfide (H2S), and any other toxics
that may be present in the space as determined by the individual responsible for supervision of the
facility’s Industrial Hygiene Exposure Assessment Program, as required by Global OE Procedure
EHS-5190, Industrial Hygiene Exposure Assessment Process, Section 5. The facility may consult
with the CPChem Corporate EHSS to identify an approved, contracted Industrial Hygienist.
1.2 Entry into confined spaces shall be PROHIBITED where any pre-entry testing detects a flammable
concentration > 10% LEL or any air contaminant concentration > 50% of its Immediately Dangerous
to Life or Health (IDLH) value identified in CPChem’s Occupational Exposure Limits (OELs) table.
Note: If an IDLH value is not included in the OEL table, consult with CPChem Corporate EHSS for
appropriate limits.
1.3 For atmospheric testing of spaces exceeding prohibited entry limits, vapor/gas freeing, degassing
and/or ventilating methods must be performed to eliminate or control hazardous atmospheres, as
recommended by accepted industry standards, such as API STD 2015, Requirements for Safe
Entry and Cleaning of Petroleum Storage Tanks (2006) and API RP 2016, Guidelines and
Procedures for Entering and Cleaning Petroleum Storage Tanks (2006).
2. Conditions Requiring Mitigation Plans and Inert Entry Procedures:
2.1 Confined Space Entry and Mitigation Plans
2.1.1 Entry into a confined space is allowed under a facility’s Confined Space Entry Program,
without a Mitigation Plan, provided engineering control(s) can achieve and
continuous/personal monitoring can confirm, the following:
2.1.1.1 Oxygen levels range ≥ 19.5% and ≤ 23.5%;
2.1.1.2 A flammable concentration = 0% LEL; and,
2.1.1.3 Toxic chemical concentration ≤ the 8-hr TWA OEL value.
2.1.2 A Mitigation Plan is mandatory per Section 4, for any confined space entry where
continuous/personal monitoring cannot confirm the conditions of Section 2.1.1.
2.2 Inert Confined Space Entry
2.2.1 Entry into a confined space by applying inerting controls (Inert Entry) is allowed under this
Directive for a confined space where introduction of air into the space may create a reactive
hazard, pyrophoric hazard, or potential degradation of contents (e.g., catalyst management),
only when all of the following requirements are met:
2.2.2.1 A flammable concentration < 10% LEL;
2.2.2.2 Toxic chemical concentration < 50% of its IDLH value;
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2.2.2.3 Oxygen concentration must be controlled to ≤ 50% of the minimum oxygen

concentration for combustion, with a maximum 4% oxygen concentration;
2.2.2.4 A written Mitigation Plan has been developed per Section 4;The facility has
developed a separate Inert Entry Procedure which addresses API STD 2217A,
Guidelines for Safe Work in Inert Confined Spaces in the Petroleum and
Petrochemical Industries (2009).
2.2.2 Any deviation from the facility Inert Entry Procedure must be approved by the Facility
Manager in writing.
3. General Requirements for All Confined Space Entries
3.1 Facilities shall develop a written Confined Space Program to address local laws/regulations,
CPChem Global OE Procedure (e.g., EHS-5190 and EHS-6350) requirements, and the elements of
this Directive.
3.2 JSA and Exposure Assessment:
3.2.1 Each confined space entry shall require a comprehensive JSA, initiated and performed by
Company personnel. The JSA shall address preparation of the confined space for entry,
work to be performed during entry, and return-to-service of the space.
3.2.2 For work involving contractors, personnel from each contractor company involved in the
entry work, must participate in the Company JSA. This shall include contractors responsible
for mobilization and set-up of equipment inside and outside of the space to support the entry
work (e.g., contracted vacuum truck operators).
3.2.3 During the JSA, the following chemical hazards shall be reviewed and documented:
3.2.3.1 The identity and nature of substance(s) last contained in the space;
3.2.3.2 Review of potential chemical, reactive, and radiation hazards, including
flammables, toxics, reactive (such as pyrophoric materials), radiation sources,
including naturally occurring radioactive material (NORM), etc. which could exist;
and,
3.2.3.3 Review of conditions which could result in an enriched or inadequate oxygen
supply for entrant breathing, such as excess air contaminants (nitrogen, etc.),
oxygen-consuming work/physical contents (e.g., welding, activated carbon, catalyst
beds, etc.).
3.2.4 Each JSA must include a review of physical hazards within the space, such as converging
walls, sloping floors, engulfment, noise, heat stress, etc.
3.2.5 All equipment to be used in the confined space must be evaluated and documented during
the JSA to ensure the equipment is appropriate for use in the space (e.g., such as ensuring
non-sparking tools, grounded/bonded hoses, and/or rated electrical equipment is used).
3.2.6 All required personal protective equipment (PPE) must be evaluated and documented during
the JSA.
3.2.7 All confined space rescue equipment must be reviewed and documented during the JSA.
The availability of confined space rescue personnel and the written confined space rescue
plan must be confirmed and documented as well.
3.2.8 For any entry where an entrant has the potential for chemical exposure above an OEL, the
individual responsible for supervision of the facility’s Industrial Hygiene Exposure
Assessment Program must determine, in writing, the acceptable PPE, including respiratory
protection, body protection, gloves, etc. The specific, required PPE shall be included in the
written JSA and appropriate PPE hazard assessments updated accordingly.
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3.3 Tools and Equipment Selection and Use:

3.3.1 Lights used inside a confined space shall be rated for Class I, Division 1 and Class II,
Division 1 locations per National Electrical Code; explosion proof; and, suitable for rough
service. Electrically-powered tools and electrical equipment, excluding lights, shall not be
permitted for use in a confined space unless a hot work permit is issued. For any work
performed in a confined space under a hot work permit, if LEL monitoring detects any
reading above 0% LEL, work shall immediately stop until the hazardous conditions are
eliminated. A new hot work and confined space permit shall be written verifying the
conditions are safe.
3.3.2 For work to be performed in a confined space where continuous/personal monitoring detects
any reading above 0% LEL, all tools, including shovels and other hand tools, and pneumatic
or hydraulic powered tools and their attachments, shall be non-spark generating.
3.3.3 When used, vacuum hoses and associated equipment both inside and outside of the
confined space shall be appropriately grounded and bonded. A qualified person shall
inspect and test the grounding/bonding system for vacuum hose(s) and vacuum equipment
and document the quantitative test results on the confined space or hot work permit.
3.3.4 Ventilation equipment must be bonded to equipment and grounded to earth.
3.4 Continuous Air Monitoring and Hazardous Atmosphere Control:
3.4.1 Monitoring practices (including pre-entry testing, continuous monitoring, and personal
monitoring) shall be established based on accepted industry standards, such as in API STD
2015 and API RP 2016 to meet the requirements of this Directive. The selected practice(s)
shall be documented in the facility Confined Space Program.
3.4.2 Facility confined space monitoring practices, including continuous/personal monitoring
methods and selection of monitoring devices, shall be reviewed and approved, in writing, by
the individual responsible for supervision of the facility’s Industrial Hygiene Exposure
Assessment Program.
3.4.3 The confined space attendant shall perform continuous monitoring of the confined space for
O2, LEL, CO, and H2S, and any other toxics as determined by the individual responsible for
the supervision of the facility’s Industrial Hygiene Exposure Assessment Program.
Continuous monitor alarm set points shall be established consistent with the settings
identified in Table 1, Alarm Set Points Requiring Confined Space Evacuation. Personnel
shall evacuate the confined space upon activation of any continuous monitor alarm, whether
momentary or continuous.
3.4.4 The confined space attendant and the confined space entrant shall wear personal monitors
for O2, LEL, CO, H2S, and any other toxics as determined by the individual responsible for
supervision of the facility’s Industrial Hygiene Exposure Assessment Program. Personal
monitor alarm set points shall be established consistent with the settings identified in Table
1. Personnel shall evacuate the confined space upon activation of any personal monitor
alarm, whether momentary or continuous.

Table 1: Alarm Set Points Requiring Confined Space Evacuation

Parameter Low Alarm High Alarm

O2 <19.5 >23.5
% LEL ≥10 ≥20
ppm CO ≥25 ≥100
ppm H2S ≥10 ≥15
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3.4.5 For toxic contaminants where continuous/personal monitoring devices are not commercially
available, the JSA and confined space permit shall specify the periodic air monitoring device
(e.g., Dräger tubes), the frequency of sampling, and the maximum permitted air
concentration of the toxic contaminants within the space. Continuous/personal monitoring of
O2, LEL, CO and H2S shall not be replaced with periodic monitoring.
3.4.6 Continuous ventilation devices supplied from clean air sources with a reliable/continuous
power supply shall be used during all confined space entries to control potential hazardous
atmospheres prior to and during work except as follows:
3.4.6.1 For Inert Entry executed in accordance with Section 2.2 of this Directive; or,
3.4.6.2 When a Mitigation Plan has been developed and approved in accordance with
Section 4, and also includes the reason(s) why continuous ventilation is not
practical (e.g., cooling tower confined space entry) and the alternative control
methods to be used to ensure LEL, O2, and toxics are maintained to conditions of
Section 2.1.2.
3.5 Work Permitting:
3.5.1 The Company shall identify each Permitting Authority, an individual(s) by job title(s), who
has ultimate signatory approval of each confined-space permit in the facility’s written
Confined Space Program. This individual with responsibility for signatory approval of the
permit shall perform the following:
3.5.1.1 Conduct a job-site walk-through to verify all conditions required by the facility’s
Confined Space Program and this Directive have been met;
3.5.1.2 Verify isolation has been performed in accordance with facility procedures (e.g.,
lock/tag/try, blinding, etc.), before issuing each permit;
3.5.1.3 Witness all pre-entry testing/monitoring to verify all conditions required by the
facility Confined Space Program have been met and documented in the permit;
and,
3.5.1.4 Ensure all conditions for entry are documented in the permit, as required by the
JSA and/or Mitigation Plan (when a Mitigation Plan is required).
3.5.2 Job-site walk-through and witnessing of tests shall not be delegated to any individual other
than the signatory approver.
3.5.3 The Company signatory approver shall deny the permit by not signing and require further
preparation or controls if the following cannot be confirmed:
• All isolations are properly in place;
• Pre-entry monitoring and other tests/inspections have been performed and meet
quantitative requirements of this Directive;
• An adequate JSA has been completed;
• A Mitigation Plan has been developed and approved by the Facility Manager (when a
Mitigation Plan is required); and,
• All other facility confined space requirements have been addressed (e.g., facility Inert
Entry Procedure followed).
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3.5.4 If any conditions differ from the requirements of the permit, the JSA, or the Mitigation Plan (if
applicable), or a personal/continuous monitoring alarm is activated, entrants shall
immediately exit the space, the permit shall be revoked, and the hazards re-assessed by a
person qualified in the permitting process. Prior to re-entering the space, pre-entry air
testing shall be performed and a new permit shall be written verifying the confined space
has returned to a safe condition for work. If any conditions changed that require the
Mitigation Plan to be revised, the Facility Manager must approve the revised Mitigation Plan,
in writing.
4. Mitigation Plan
4.1 Where a Mitigation Plan is required as indicated in Section 2, the Mitigation Plan for entry into the
confined space shall include the following:
4.1.1 Review and evaluation of the JSA by a representative from the facility’s Safety and Health
organization to ensure the JSA was comprehensive and adequate;
4.1.2 Additional review of the chemical and physical hazards known to exist within the space and
evaluation of alternatives to further reduce the hazards before making entry into the space;
4.1.3 The specific engineering controls and standards being applied for control of hazardous
atmospheres while work is performed within the space, such as ventilation;
4.1.4 Inclusion of specific air monitoring requirements; appropriate PPE; emergency response
planning, including rescue team and equipment availability; and, any other necessary
safeguards; and,
4.1.5 For Inert Entry, an evaluation as to how the work is being performed in accordance to the
facility’s Inert Entry Procedure to address the conditions of API 2217A.
4.2 Mitigation Plans must be developed by a cross-functional team of facility experts, and must always
include the individual responsible for supervision of the facility’s Industrial Hygiene Exposure
Assessment Program.
4.3 Each Mitigation Plan must be approved by the Facility Manager, in writing, prior to entry.
5. Training and Competency
5.1. Each Company individual designated to be a signatory approver for confined space permits shall
receive classroom training and successfully demonstrate competency for each element of the
confined space permitting process. Competency of classroom training shall be performed by
written examination in addition to on-the-job skill demonstration. Upon demonstrating competency,
a Learning and Development Roster (or equivalent form) shall be used to document that training
has been performed and competency has been evaluated as acceptable. Copies of completed
rosters shall list persons qualified to approve confined space permits and shall be maintained on
site.
5.2. Face-to-face information sessions to communicate this Directive shall be performed by qualified
Company personnel with all individuals having a role in permit-required confined space entries (i.e.,
permit writers, entry supervisors, entrants, attendants, rescue team members, personnel
responsible for atmospheric testing, personnel required to sign the permit, etc.). The information
sessions shall address all the elements of this Directive. A Learning and Development Roster (or
equivalent form) shall be used to document that these discussions have been performed.
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6. References
• 29 CFR § 1910.146, Permit-required confined spaces, U.S. OSHA
• API STD 2015, Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks (2006)
• API RP 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks
(2006)
• API STD 2217A, Guidelines for Safe Work in Inert Confined Spaces in the Petroleum and
Petrochemical Industries (2009)

CONTACTS
For additional information regarding this Directive, please contact any of the individuals below.

CONTACT NAME TITLE PHONE NUMBER E-MAIL

Kevin Collins Manager, Process Safety Management 832-813-4302 [email protected]
Ron Lewis Manager, OE, Safety & Health 832-813-4420 [email protected]
Eric Van Tol Occupational Health Manager 832-813-4683 [email protected]
Scott Haney OE Implementation Services Manager 832-813-4787 [email protected]

This document is CONFIDENTIAL and intended for ONSITE FACILITY use only.