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Freeport Safe Work Permit Standard MOC Summary of Changes. Why Change?. Dow Global EH&S Standards have been reviewed and the requirements have been reduced and simplified,
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Why Change? • Dow Global EH&S Standards have been reviewed and the requirements have been reduced and simplified, • hROH EH&S Standards have also been reviewed and the requirements between the Dow and hROH Standards have been harmonized into one standard, • Freeport Additions to the global standard have been reviewed and all Freeport specific additions to the global SWP standard have been removed. • This will allow TXO to align with global training tools and minimize resource burden to incorporate Freeport additions.
Summary of Changes to the SWP Standard New Requirement in Global SWP Standard Modified Requirement in Global SWP Standard Deleted Requirements in Global SWP Standard Deleted Freeport Additions to SWP Standard (The only difference in Freeport vs. Global standard that will remain is the SWP template) 1 1 6 All
Summary of Changes • One NEW requirement: • It is required to document the transfer of a SWP to another permit issuer. • If the Personnel Issuing a Safe Work Permit leaves the work site while work is still being done and can no longer perform his/her responsibilities (for example at the end of shift), then: • The Safe Work Permit is required to be transferred to another person who is authorized to issue a Safe Work Permit. The person to whom the safe work permit was transferred is required to assume the role and responsibilities of the Personnel Issuing a Safe Work Permit and shall communicate this change to the Personnel Accepting the Safe Work Permit and, • The issuer to whom the safe work permit was transferred is required to review the status of active Safe Work Permits and the status of affected equipment in their area of responsibility, and • The issuer to whom the safe work permit is transferred is required to insert name and signature on the safe work permit.The new issuer must be authorized to issue the type of permit that is being transferred.
How to document the SWP transfer? Current SWP Must document transfer by both printing and signing the SWP Space for Transfer on SWP header New SWP (begin roll out in September 2012)
Summary of Changes The Transfer Process • The original SWP Issuer communicates to the new SWP Issuer the status of permits that are currently active. • The New SWP Issuer shall review the SWP and print their name and sign the yellow copy of the SWP if they accept ownership. The New SWP Issuer can choose cancel the permit and reissue a new permit. • There is no joint job site inspection required between the original SWP Issuer and the new SWP Issuer. • The New SWP Issuer will then visit the job site to review the status of the job and print/sign the white copy of the SWP (the copies do not need to be brought together) • The New SWP Issuer shall communicate the transfer to the SWP receiver.
Transferring SWP’s When is a SWP Transfer required? From the Standard: If the Personnel Issuing a Safe Work Permit leaves the work site while work is still being done ANDcan no longer perform his/her responsibilities. Describe some scenarios when a transfer would be required? What does it mean to leave the work site? • Typically, this means to leave the facility where the work is being done. For example, leaving the block. Some work groups, Site Pipeline Operations for example, have very large areas to cover. These groups must define their process for how proper communications can be maintained to ensure that proper oversight of the work and that the permit issuer can fulfill their duties.
Transferring SWP’s When is a SWP Transfer required? From the Standard: If the Personnel Issuing a Safe Work Permit leaves the work site while work is still being done ANDcan no longer perform his/her responsibilities. What are the SWP Issuers responsibilities after a permit is written? • From the Standard: • During the work, the Personnel Issuing a Safe Work Permit or his/her designee shall: • Ensure that Personnel Accepting a Safe Work Permit are notified of any changing conditions that could present a hazard to the workers. • Conduct additional on-site inspection(s) to ensure that the safe working conditions upon which the Safe Work Permit is based are maintained. • Suspend until re-authorized or cancel the Safe Work Permit if the safe working conditions are not maintained.
Transferring SWP’s What if the SWP Issuer leaves suddenly without transfer? • Another SWP Issuer must assume responsibility for the SWP and sign on to the permit. If none are available the SWP must be suspended until a new SWP Issuer can be identified. • The new SWP Issuer should perform a field visit and gain understanding of the entire scope of work.
Summary of Changes to the SWP Standard New Requirement in Global SWP Standard Modified Requirement in Global SWP Standard Deleted Requirements in Global SWP Standard Deleted Freeport Additions to SWP Standard (The only difference in Freeport vs. Global standard that will remain is the SWP template) 1 1 6 All
Summary of Changes • Removed Requirements that are redundant and are covered in other standards. • Documentation requirements for checklist retention have been removed and are found in other standards. • Specific requirements for specialty permits such as L&EO, HW or CSE. • For example: there were requirements in the SWP standard for how to demonstrate equipment is clear for L&EO first breaks. This detail will be provided in the L&EO standard through requirements, guidelines and training. • Removed Freeport additions that provided instruction on how to complete the SWP. These clarifications and instructions will be covered in SWP training and SWP template instructions.
Summary of Changes • With the removal of the Freeport Addition, some links will be lost in the standard: • The link to the Freeport SWP Exempt Job Process and List will be re-established in each departments WebEDMS for quick access. • The Extended Duration process documents formerly linked in the standard will be added to the Freeport EH&S WebEDMS database and links will be provided on the Freeport EH&S Webpage for easy access. • Procedure for extended duration permits • Extended duration request form • Extended duration job aid • Exempt and extended duration crew rosters
SWP Template Changes • Template changed to conform more closely with global SWP template while still meeting needs in Freeport. • Template changed from 8.5”x14” to 8.5”x16 ¾“ • L&EO and Hot Work Checklists added back to front page of Permit • Scaffold inspection and LCG sections have been removed. • Minor additions to the list of checklists to conform with other Freeport requirements. • Minor changes to hazards section.
SWP Template Changes Everything is BIGGERinTEXAS! New permit is 2 ¾ “ longer
New SWP Template Header OLD New location for Plant/Dept NEW Better layout of co-signature info with Plant/Dept addition New line to document SWP transfer New check box to indicate when a crew roster is used. A template for a crew roster will be provided More room for worker names
New SWP Template – Section I.1 MODIFIED You asked for it, you got it! More room for writing in scope of the job to be completed
New SWP Template – Section I.1 Max Duration of SWP added to the template MODIFIED
New SWP Template – Section I.1 MODIFIED Prompt to review addendums. Yes or N/A More room for RTM #
New SWP Template – Section I.1 MODIFIED Added check boxes for some Texas standards M79:Appendix A is required whenever work must be done on an incomplete scaffold. This is not required for building, modification or removal of scaffold by qualified scaffold builders. Link to M-79
New SWP Template – Section I.1 MODIFIED Added check boxes for some Texas standards O-47 Checklist is required with the SWP whenever X-ray, lasers or other radiation sources are used in the work scope. Link to O-47
New SWP Template – Section I.1 MODIFIED Added check boxes for some Texas standards The Sensitive and Critical Equipment Checklist is required to be filled out by the crew performing scaffolding and insulation work. The permit issuer should review it and use their knowledge of the process area to ensure all sensitive and critical equipment in the area are identified. Link to Checklist
New SWP Template – Section I.1 MODIFIED Added check boxes for some Texas standards E-88 requires that for any work on electrical wiring or equipment 480V or above, that an Electrical Safe Work Permit (ESWP) or an Electrically Cleared Tag (ECT) is used. Link to ESWP Form(NOTE: MOC/Training is currently being rolled out for these changes) This is what an ECT looks like
New SWP Template – Section I.2 MODIFIED 2g moved to this section to review facility specific information on back of SWP. If a facility does not have facility specific information on the back of the permit than N/A
New SWP Template – Section I.4a MODIFIED a This is where we will communicate whether an on-site inspection is required at close-out This question previously existed in Section IV – Closeout.
New SWP Template – Section I.5 MODIFIED a a a a a Added Asphyxiation hazard Added Hazards: -Vibration -Slips/Trips or Congestion -Falling Objects Space for thermal stress level (H1-H4)
New SWP Template – Section I.6 MODIFIED a a Elevated Work Section has changed: • Expanded Gloves Section with common gloves listed to select. • If more than 1 glove is selected, then that indicates that both are required. If intended to be an option please clarify with a comment • Expanded Gloves Section with common gloves listed to select. • For chemical gloves, check other and list the specific kind. “Rubber” is not adequate. Must make sure that the specific gloves are specified for the chemicals involved. If there is work >6 ft, then a Fall Prevention method is to be checked. Select Harness/Lanyard type -if Lifeline is used circle horizontal or vertical Describe Anchor Points -if more room is needed, note to see comments
New SWP Template – Section II and Section III ADDED L&EO and Hot Work Checklists From L&EO Team From Hot Work Team Training for L&EO and Hot Work Checklists to be provided by L&EO and Hot Work Training Presentations.
New SWP Template DELETED • But Why? • Does not conform to Global Template • Reached habit strength with identification of when LCG’s apply. • Fall Mitigation plan triggered by identification of Critical Elevated work in scope. • Contractor scaffold inspections are documented on the scaffold tags and can be audited independently.
Summary of Changes to the SWP Standard New Requirement in Global SWP Standard Modified Requirement in Global SWP Standard Deleted Requirements in Global SWP Standard Deleted Freeport Additions to SWP Standard (The only difference in Freeport vs. Global standard that will remain is the SWP template) 1 1 6 All
Summary of Changes (for Facility Leaders) • One requirement has been modified: • Old Standard: Facility owner and the facility that has operational control decides who shall issue the SWP • New Standard: The facility department owner shall coordinate with facility/ department who has operational control of the work activity to decide who has the responsibility for issuing the Safe Work Permit • Removal of the requirement for Facility/Work Group Leadership to: • Maintain lists of authorized personnel (Permit Issuers), • Document Authorized Operating Procedure Users by name or role, and • Annually review the list of activities that do not require a Safe Work Permit.