Document Z40kXmXVZvBozZpqJqrLj8VL

M-*2 (Rv.'v. 5-7*) Shell Oil Company Interoffice Memorandum JANUARY 15, 1982 e'cc Fa.' & PLAINTIFF'S EXHIBIT SH-1392 FROM: MANAGER, HEALTH & SAFETY, OPERATIONS TO: @ GENERAL MANAGER, DEER PARK MANUFACTURING COMPLEX MANUFACTURING COMPLEX MANAGERS MARTINEZ WILMINGTON NORCO WOOD RIVER REFINERY MANAGERS ANACORTES ODESSA/CINIZA PLANT MANAGERS DENVER METAIRIE EL PASO MOBILE GEISMAR TAFT MARIETTA WOODBURY DISTRIBUTION AREA MANAGERS EAST SOUTH MIDWEST WEST MANAGER, RAW MATERIALS SUPPLY SUBJECT: RESPIRATOR USE GUIDELINES Further to previous communications on the above subject, corporate agreement 'tias been reached on the attached guidelines for respirator use. You will note that the format has been condensed, but the provisions and criteria should not be different from what you have seen before except for the provision for exceptions in the third paragraph. If you have any further questions, please call me. Attachment cc: See attached distribution list LAM 024475 For information Shell Pipe Line Corporation - Manager Employee Relations Supervisor Safety, Health & Training ABs-007664 t ' DISTRIBUTION LIST i DEER PARK MANUFACTURING COMPLEX SUPERINTENDENT, HEALTH AND SAFETY REFINERY SAFETY MANAGER CHEMICAL SAFETY MANAGER MARTINEZ MANUFACTURING COMPLEX MANAGER, HEALTH AND SAFETY NORCO MANUFACTURING COMPLEX SUPERINTENDENT, HEALTH, SAFETY AND ENVIRONMENT MANAGER, HEALTH AND SAFETY WILMINGTON MANUFACTURING COMPLEX MANAGER, SAFETY AND INDUSTRIAL HYGIENE - WOOD RIVER MANUFACTURING COMPLEX MANAGER, SAFETY AND INDUSTRIAL HYGIENE ANACORTES REFINERY SAFETY MANAGER ODESSA/CINIZA REFINERIES SAFETY REPRESENTATIVE, ODESSA SAFETY REPRESENTATIVE, CINIZA DENVER PLANT MANAGER, SAFETY AND INDUSTRIAL HYGIENE EL PASO PLANT SAFETY REPRESENTATIVE GEISMAR PLANT . MANAGER, HEALTH, SAFETY AND ENVIRONMENT MARIETTA PLANT MANAGER, HEALTH, SAFETY AND ENVIRONMENT METAIRIE PLANT SAFETY ENGINEER MOBILE PLANT MANAGER, HEALTH, SAFETY AND ENVIRONMENT TAFT PLANT SAFETY REPRESENTATIVE WOODBURY PLANT MANAGER, HEALTH, SAFETY AND ENVIRONMENT HEAD OFFICE MANAGER, HEALTH ANO SAFETY, PRODUCTS DISTRIBUTION SUPERINTENDENT, TERMINAL OPERATIONS, DOMESTIC SUPPLY OPERATIONS LAM 024476 ABS-007655 / PRODUCTS OPERATIONS RESPIRATOR USE GUIDELINES Respirators are considered to be an appropriate option for reducing inhalation exposures to harmful materials. When they are required, it is our primary objective to reduce the risk of harm to the employee; however, where practical and consistent with local regulations, we also do not want to unnecessarily restrict personal choice with regard to wearing facial hair. The basis for determining that a respirator is required for a particular job or task should be the potential inhalation exposures associated with that job or task. The criteria for establishing fit should be based on the potential health risk of that exposure. These guidelines provide for classifying jobs and activities into three cate gories with associated requirements as shown below. Where individual situations are believed to warrant consideration of exceptions, proposed plans and controls should be agreed to by Manager, Health & Safety, Operations and appropriate HS&E personnel. Cat. Job Related Inhalation Health Risk I Insignificant ___________________ Requirements Respirators not required for health reasons. If used, fit requirements (if any) are up to local management. lam 024477 ABS-007656 2 Cat. II Job Related Inhalation Health Risk Long term or chronic __________________ Requirements Physically able to wear a respirator. Air-purifying apparatus. - Pass an appropriate fit test and - Be free of established facial hair in the seal area. Air-supplied or self-contained breathing apparatus. - Be free of established facial hair in the seal area or^ - Pass a test that establishes a leak rate suitable for them to perform their work assignment. III Immediately life threatening ,, Physically able to wear a respirator, Use an air-supplied or self-contained breathing apparatus and - Be free of established facial hair in the seal area or - Pass a test that establishes a leak rate suitable for them to perform their work assignment. Classification of jobs or activities should consider the potential for exposure during routine operation, upset/emergency conditions, and shutdown conditions any one or all of which may be controlling. In addition, scheduling flexibility may sometimes require a particular job assignment to be placed in a higher-risk category. Potential exposure and risk also are the basis for the respirator requirements applicable to contractors, visitors, observers, vendors, etc. That is, if LAM 024478 ABS-007657 3 contractors or outsiders are performing work activities that fall ftito Categories II or III, they should be subjected to the same criteria as apply to regularly assigned location people. However, in general, people not assigned to field activities, such as office workers, visitors, observers, vendors, etc., are expected to escape during an emergency condition. As such, respirator usage would not normally be required. LAM 024479 ABS-007658 INERT ENTRY -P-R--O--C--E--D--U-R--E----R--E--C-O--M---M---EN--DAT--IO--NS Premise Oxygen deficient atmosphere (inert) entry subject personnel to conditions that can be immediately hazardous to life. w Inert entry will not be authorized until all alternates have been Reviewed with and inert entry has been authorized by a designated member of the fenior Management Team. General A Shell coordinator will be appointed to overview the project. The Shell coordinator will schedule a meeting with the contractors, field supervisors, and all involved departments to discuss the job procedure and equipment. ft Minimum Safety Requirements 1. Contractor's equipment must meet all legal requirements and be acceptable to Shel1. 2. Contractor's supervisors and workers' training and experience must meet all legal requirements and be acceptable to Shell. 3. The vessel shall be purged with inert gas until the concentration of hydrocarbon vapors in the effluent is non-flammable in air. LAM 024480 4. The vessel shall be blinded and/or completely isolated except for the inert gas purge lines. The inert line shall be isolated from all other systems. ABS-007659 / 2 5. The flow of inert gas into the vessel shall be maintained at a rate to'* assure air cannot enter through any openings. 6. Temperature indicators and recorders connected to the reactor shall remain in service and be monitored during the entire purging and catalyst removal operations. Entry shall not be permitted until cool (100 or ambient air temperature). 7. Signs shall be posted in all areas necessary to warn personnel not to expose themselves to reactor effluent. 8. When the manway (or top ELL) is removed, the vessel atmosphere shall be checked immediately for the undesirable vapors (oxygen, HC vapors, NiC04, etc.). 9. All points of entry must be identified with signs indicating inert atmosphere and indicating respiratory equipment is required. 11. A written permit shall be issued to the contractor jointly by the departments involved. The permit will indicate the vessel conditions. The permit may be withdrawn at any time by a Shell employee. 12. The Shell coordinator will require the contractor's field supervisor to supply a written outline of his procedure requirements including the names of all workers on the job. LAM 024481 ABS-007660 The minimum requirement of the contractor would include: 1. All protection equipment and facilities must be serviced and inspected. Respirable air must contain at least 20% oxygen. 2. Personnel entering vessel should be provided with two separate sources of respirable air and equipped with: a. Suitable clothing. b. Parachute-type harness with safety line to outside unless entry is from the side of the vessel. c. Full respiratory face-piece with positive pressure air supply. 3. Standby man at manway to be equipped for entry as well as in continuous communications. -4. Every employee inside the reactor to be in visual contact with another man. 5. All men to be instructed in conditions to be encountered and trained in the use of respiratory and communications equipment. 6. If entry of a vertical vessel is through manway at top, hoist to be available at all times above manway for emergency rescue work. 7. If air tools are used, they must be operated by CO free inert gas; or if air must be used, attach an exhaust hose to outlet on tool and lead exhaust out of vessel. LAM 024482 ABS-007661 4 8. Atmosphere of work area in vessel to be tested regularly. 9. At ground level, there shall be an instrument panel to monitor flow and pressure of each primary and the secondary source of breathing air. Instrumentation also shall provide visual and audiable alarms for minimum flow and pressure for each air supply. 10. Personnel directly involved in the operation shall have communication with each other by a sound powered or intrinsically safe electrical phone system. At the air instrument panel, provisions shall be made for communication with individuals of the crew by the air monitor, crew supervisor, or other involved personnel. 11. Any problem affecting the personal safety of any crew member shall be cause for immediate removal of all personnel from the reactor. LAM 024483 ABS-007662