HSE&S Procedure No. 19.
05-03
Revision No. 07
Page 1 of 10
Lotte Chemical Pakistan Limited
Port Qasim
HSE&S Procedure No.
PROCEDURE NO. Page 1 of 10
19.05-03
TITLE Entry into Confined Spaces
WRITTEN BY P A A Finnegan Date: October 1996
REVISED BY Sikandar Khan Date: January 2019
Umair Khalid Date: March 2019
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REVIEWED BY Syed Masood-Ul-Hassan Date: March 2019
Syed Qamar Alam Date: March 2019
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APPROVED BY Tariq N Virk C Date: March 2019
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ISSUE DATE March 2019
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Changes w.r.t organizations & designations
Contents
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Page No.
1. Purpose 2
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2. Scope 2
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3. Definitions 2
4. Requirements 3
5. Communication & Training 9
6. Documentation 9
7. References 10
8. Amendments 10
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1. PURPOSE
This instruction covers the procedures and precautions, which shall be observed
before anyone is permitted to enter a “Confined Space”, to prevent danger to life or
health caused by breathing a dangerous atmosphere.
2. SCOPE
This procedure applies to Lotte Chemical Pakistan Limited (LCPL) employees and
contractors at the LCPL Site, Port Qasim, in particular to Plant Managers, Senior Shift
Managers, Shift Managers, PTW Acceptors and all personnel trained as standby men.
It does not cover entries to confined spaces using Breathing Apparatus, they are
covered in Ref 7.5.
3. DEFINITIONS
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3.1 Dangerous Fumes
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Dangerous Fumes include any gas or vapour which could cause acute health
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risk and hence extends to oxygen excess as well as deficiency. Dangerous
Fumes may arise from residue left from the normal duty of the equipment,
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from vessel purging and preparation, from ingress from adjacent plant or from
the task being performed in the Confined Space.
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3.2 Confined Space
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A confined space is any item of plant equipment or civil structure enclosing a
space at least large enough for entry and where there is liable to be present,
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dangerous fumes or a deficiency in oxygen. Holes in the ground shall be
included if more than one meter deep and presenting a significant hazard
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depending on the nature of the site. The pipe trench area of Utilities Plant is
exempted from this where oxygen deficiency and dangerous fumes are not
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liable to be present.
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3.3 Entry
Entry shall include the insertion of the head into an opening in a confined
space (including drains) where dangerous fume or oxygen deficiency can be
present.
3.4 Entry Permit
The form issued by Authorized Persons which certifies that a confined space is
safe to enter. (See Appendix-1).
3.5 Threshold Limit Value (TLV), Maximum Exposure Limit (MEL),
Occupational Exposure Standard (OES)
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These are all terms which define exposure limits for hazardous substances,
below which people can work day after day without adverse effects. They are
quoted as 8 hour time weighted averages.
3.6 Class ‘A’ Entry
An entry into a confined space where breathing Apparatus need not be worn.
3.7 Class ‘B’ Entry
An entry into a confined space where Breathing Apparatus shall be worn. (Ref
7.5)
3.8 Vessel Register
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A plant manual which records details of vessel isolations (physical,
radioactive and electrical), methods of cleaning for entry, rescue plans,
methods of ventilation and positions for atmosphere testing.
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3.9 Rescue Plan C
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The method of rescuing a person from a confined space and indicating the
maximum number of entrants allowed.
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3.10 Authorized Person
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Plant Managers and Senior Shift Managers are Authorized Persons who have
been nominated by the General Manager Manufacturing after training and
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validation. In some cases trained and validated Shift Managers are also
Authorized Persons.
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4. REQUIREMENTS
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4.1 Principles
4.1.1 No person shall enter a confined space without prior written
authorization from an Authorized Person.
4.1.2 Authorized persons shall only give written authorization after personal
examination of the confined space and its isolation and shall define the
conditions under which entry is permitted.
4.1.3 All practical steps shall be taken to ensure that safe entry can be
achieved without the need for breathing apparatus.
4.1.4 Confined spaces shall not be considered fit for entry with or without
breathing apparatus unless the concentration of hazardous gases is
below the appropriate exposure limit and the oxygen content is
between 20 and 21% v/v.
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NOTE: Entry to vessels where the atmosphere is irrespirable or would cause
immediate danger to life, shall not be permitted.
4.1.5 Entrants shall leave their Company Identification Card with the
Standby Man (SBM). Anyone without Identification Card will require
written permission from concerned Plant Manager to enter into the
Confined Space which will be left with SBM. He shall enter the names
of entrants with entry and exit time on the specific form provided to
him. For Standby man / Boardman entry sheet format (See Appendix-
9)
4.2 Preparation of Confined Space for Entry
While confined spaces are being prepared for entry, PTW Issuing Authorities
shall prevent access by installing a physical barrier until an Entry Permit has
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been issued. Access is to be prevented by barrier after the man way has been
opened by Mechanical Department. This barrier shall clearly indicate that
entry is forbidden.
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4.2.1 Isolation C
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All lines and pipe work on vessels shall be isolated as close to the
vessel as possible either by physical disconnection or the use of
standard full thickness slip-plates. Lines that are physically
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disconnected shall be blanked at the open end away from the vessel
(Ref 7.2). During plant overhaul when the area is declassified, slip
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plates can be omitted on certain lines for vessel entry. For this, a
separate slip plate register for that particular vessel duly approved by
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the respective plant manager should be obtained clearly stating “FOR
OVERHAUL ONLY”.
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Each plant shall maintain a vessel register which defines the isolation
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method for each vessel. See Section 3.8.
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4.2.2 Motive Power
Where a vessel is fitted with power driven equipment (e.g. Agitator) a
positive isolation of power shall be made by racking out and locking
off the circuit breaker. In addition, one of the following shall be carried
out, where applicable.
Disconnection of the drive coupling.
Removal of Electrical supply cable from the drive motor.
Removal of belts from belt-driven equipment.
The procedure is not applicable for the following entries:
C1-608A-T DH Column Condenser Fans
C1-1505A-D Vent Scrubber Condenser Fans
C1-805A-D Dump Steam Condenser Steam
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C1-2400A-D Off-Plot Cooling Tower Fans
C1-2440 Off-Plot 5th Cooling Tower Fan
G1-301 Oxidation Reactor Agitator
G1-401 First TA Crystallizer Agitator
M1-423 TA Drier
M1-428 TA Drier Pony Motor
P1-422 TA Drier Feed Screw
M1-1423/1 PTA Drier
P1-1424 PTA Drier Feed Screw
Isolation for these electrical drives for vessel entry shall be carried out
using multi-hasped locks. The procedure is defined in Appendix-2.
Maintenance & Inspection Manager shall ensure any requirement for
preventing MI-423, MI-1423/1 rotation and/or free movement of dryer
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feed screw if required.
Each Plant shall maintain a vessel register that defines the electrical
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isolation method for each vessel entry. See Section 3.8.
4.2.3 Radioactive Source
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Sources mounted internally shall be withdrawn into the holder and the
shutter locked, sources mounted externally shall have the shutter
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locked in the closed position. This work shall be carried out on a PTW.
(Ref 7.1). The details of radioactive isolation shall be defined in the
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vessel register.
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4.2.4 Cleaning
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Plant Managers shall define the methods of cleaning and they shall be
recorded in the vessel register. Any silos or vessels containing powder,
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resin or granular material shall be emptied before entry is permitted.
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4.2.5 Ventilation
The PTW Issuing Authority shall ensure that vessels that had contained
flammable liquids shall be purged with steam (where applicable) and
then with air prior to entry. Confined spaces shall be adequately
ventilated by the removal of manholes / branches, supplemented by air
moving equipment. DO NOT USE OXYGEN. Air hoses directly into
the vessel are not permitted for ventilation purposes. Air mover valves
are to be tagged as "Safety Equipment"
4.2.6 Atmosphere Testing
Before entry is made to a confined space, the atmosphere shall be
sampled and tested by persons trained and Authorized by the Senior
Laboratory Officer. Generally the sample shall be tested at 3 points,
bottom, middle and top unless otherwise specified in vessel register.
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He shall record and initial the analytical results in Section 2 of the
Entry Permit. The atmosphere shall be safe if: -
The oxygen content is between 20% and 21% v/v.
The explosimeter test, if relevant, is less than 5% LEL.
Concentrations of hazardous substances are below their
appropriate exposure limit (See Section 3.5).
Sampling / testing shall be carried out as close as possible to the time
of entry and shall not be more than 4 hours before entry in any
circumstance. The Authorized Person shall request either continuous or
further periodic testing if there is any possibility of deterioration of the
quality of the atmosphere in the confined space.
In addition to the atmosphere testing above, vessels that have
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radioactive level devices shall be checked for radiation to ensure there
is no problem with locked off sources. This check shall be carried out
prior to the first Entry Permit that is issued and the result recorded in
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Section 2 of the Entry Permit. Senior Shift Manager will carry out the
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radiation check. Radiation meter shall be with ERT.
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4.3 Issue of Confined Space Entry Permit (Class “A” Entry)
4.3.1 Section 1 Reason for Entry
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The Authorized Person shall complete this section following
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discussion with the accepting authority.
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4.3.2 Section 3 Check List
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Once the vessel / confined space have been prepared for entry it shall
be inspected by an Authorized Person. He shall consider all the items
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noted in this section and tick every box. He shall sign this section to
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indicate he has carried out all the checks.
4.3.3 Section 4
The Authorized Person shall sign this section to indicate that the vessel
/ confined space:
Is isolated from all sources of dangerous fume
Does not contain sludge or deposits likely to give off fumes
Has been ventilated, the atmosphere tested and is fit to breathe.
And
The proposed activity will not create an atmosphere, which is
deficient in oxygen, is toxic or unpleasant to breathe.
4.3.4 Section 5 Class ‘B’ Entries
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If the Authorized Person is not satisfied that the requirements
stipulated in Section 4.3.3 have been met and vessel / Confined space
entry is absolutely necessary, then Breathing Apparatus shall be worn
and the procedure in (Ref 7.5) shall be used.
4.3.5 Section 6 precautions for normal Class “A” Entries
The Authorized Person shall specify in Section 6 those precautions
necessary for entry. The following precautions shall be taken for all
Class ‘A’ Entry Permits:
Provision of trained standby man who can observe personnel
within the confined space. These are the individuals capable of
understanding the relevant contents of PTW, Hot Work Permit
and Rescue Plan. (See Appendix-4 for duties of standby man).
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Provision of escape sets for all personnel inside the confined
space. This requirement can be waived off by the Authorized
Person in case of holes or excavated pits in the ground, or
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inside civil structures which are completely open to
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atmosphere, and where oxygen deficiency or dangerous fumes
are not liable to be present.
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Provision of one 30 minute breathing apparatus set for the
standby man to wear during a toxic emergency. This
requirement is only applicable for entries in core plant area,
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raw materials offloading area, and ETP area.
Rescue Plan available and made known to all concerned.
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No electrical equipment rated above 110 V is permitted inside
the confined space.
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Note: Provision of BA sets is not necessary for all Class ‘A’ entries
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when the whole Plant is shutdown. Relaxation of this precaution can be
achieved using (Ref 7.4).
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In addition to the above, the Authorized Person shall give
consideration to the need for additional precautions depending on the
nature of the confined space and the work to be performed. The
following items shall be considered:
Dye penetrate and Magnetic Particle Testing
Burning, welding, grinding operations (Appendix-5)
The use of air-operated equipment in the confined space
(Appendix-6A)
Leak testing of equipment within a confined space (Appendix-
6B).
Clamping of freewheeling electrical equipment (e.g. Agitator
paddle or fan blade).
The Authorized Person shall indicate in Section 6 of the Permit those
additional precautions that he considers necessary.
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4.3.6 Section 7 Issue
When Section 6 has been completed the Authorized Person shall issue
the Entry Permit by signing in Section 7. He shall brief entry permit
user and PTW Acceptors on the content of the Entry Permit prior to the
issue of any PTWs issued under the Entry Permit.
4.4 Validity of Entry Permits
Permits are valid from time of issue for the period stated by the Authorized
Person or until earlier cancellation. The maximum period of validity for an
Entry Permit is 24 hours, revalidation is required at each issuing and / or
Authorized Person change. (Section 9 of Permit).
4.5 Withdrawal of Entry Permit and Permit to Work.
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On completion of the work defined by the PTW’s the Issuing Authority and
PTW Acceptor shall:
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Check that no person or equipment is left in the vessel
Check that there is no further need for entry.
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Ensure physical barrier in place prohibiting unauthorized entry
Withdraw the entry permit
Sign off the PTWs for which entry permit was needed
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Ensure the Authorized person cancels the entry permit in Section 8.
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4.6 Electrical Equipment
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Electrical equipment is particularly hazardous to use inside a vessel, mainly
because the user is very well earthed through the metalwork of the vessel: this
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means that if the equipment has an electrical fault, a potentially lethal current
will flow through his body to earth.
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To protect the user, electrical equipment should be avoided wherever possible;
if it is used, it should be as low a voltage as possible. The maximum voltage
normally allowed inside a vessel is 24 Volts for portable lights. Under some
circumstances in dry vessels, 110 Volts equipment (not lights) is allowed,
provided the equipment has been specifically approved for those conditions by
one of the following people:
1. Electrical and Instrument Manager
2. Deputy Manager Electrical
3. Assistant Manager Electrical (Core Plant & Hazardous Areas)
4. Assistant Manager Electrical (Utilities & Co-Gen)
5. Assistant Manager E&I Reliability & Modification
6. Assistant Engineers Electrical
Hand-held lamps above 24 Volts shall not be used. No equipment above 24
Volts shall be used inside a wet vessel.
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Approval shall be done in writing on the form shown in Appendix-8. When
completed, it shall be kept with the vessel entry permit.
Electrical equipment inside a vessel shall only be supplied from a transformer
provided by the electrical department specifically for that purpose.
Transformers shall never be taken into a vessel. Electrical sockets shall not be
placed inside a vessel.
Each electrical cable that enters a vessel through a man way shall be supported
at the top of the man way to prevent damage from people entering or leaving
the vessel.
4.7 Rescue Plans
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Rescue Plans shall be prepared by HSE & Technical Training Manager /
Assistant Manager QHSE for all vessels and maintained in the rescue plan
database. HSE & Technical Training Manager shall consult with the
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respective Plant Manager for the production of rescue plans. A rescue plan
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should also state the maximum number of entrants allowed in the vessel at a
time. A model rescue plan with guidelines is included in Appendix-7. Rescue
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plans shall be tested as part of the emergency exercise schedule.
5. COMMUNICATION AND TRAINING
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5.1 Authorized persons shall be trained by the HSE & Technical Training
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Manager and the formal validation shall be authorized in writing by the
General Manager Manufacturing, See Appendix-3.
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5.2 Appropriate Plant Managers shall give all Line Managers training on this
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Procedure.
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5.3 All standby men shall be trained / validated by the HSE Department.
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5.4 ERT to be trained and validated for rescue plans by the HSE Department.
5.5 Line Managers shall ensure that any staff involved in the vessel entries are
trained in the use of 10 minutes escape sets.
6. DOCUMENTATION
6.1 Appendix-1 Entry Permit
6.2 Appendix-2 Multi-Hasp Locking Procedure for Special
Entries
6.3 Appendix-3 List of Person who are Authorized to Issue Entry
Permit
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6.4 Appendix-4 Entry into Confined Spaces – Standby Man’s
Duties
6.5 Appendix-5 Guidance on Heating, Cutting and Welding in
Confined Spaces
6.6 Appendix-6A Compressed Air
6.7 Appendix-6B Leak Testing of Equipment within a Confined
Space
6.8 Appendix-7 Vessel Entry Rescue Plan
6.9 Appendix-8 Approval to use Electrical Equipment in a dry
vessel
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6.10 Appendix-9 Confined Space Roll Call Sheet
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7. REFERENCES
7.1 HSE&S Procedure No. 7.11.01
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Control of the Use of Sources of Ionizing
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Radiation
7.2 HSE&S Procedure No. 19.05-01 Permit to Work Procedure
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7.3 HSE&S Procedure No. 19.05-04 Control of Hot Work Procedure
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7.4 HSE&S Procedure No. 1.01-02 Dispensation Procedure
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7.5 HSE&S Procedure No. 19.05-02 Entry into Confined Spaces Using
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Breathing Apparatus
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8. AMENDMENTS
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This is the seventh revision.