North America Onshore Environment, Health and Safety
(EH&S) Practices
Safe Work Permits
P103
SUNCOR ENERGY INC.
Manager of EH&S,
North America
Onshore
Thomas Brown
11/03/18
Reformatted into new
template
11/10/29
Document Owner
Document Contact
Date Developed
(YY/MM/DD)
Revision Date
(YY/MM/DD)
Summary of Changes
(if applicable)
North America Onshore
EH&S Practice
Safe Work Permits
Number:
P103
Table of Contents
1. Purpose ..............................................................................................................................3 2. Scope ..................................................................................................................................3 3. Responsibilities .................................................................................................................3 3.1 Site Supervisor .......................................................................................................3 3.2 Operating Authority.................................................................................................4 3.3 Performing Authority ...............................................................................................5 3.4 Gas Atmosphere Tester .........................................................................................5 3.5 Safety Watch ..........................................................................................................6 3.6 Fire Watch ..............................................................................................................6 3.7 Rescue Team .........................................................................................................6 3.8 Contractors .............................................................................................................7 4. Requirements .....................................................................................................................7 4.1 Administration .........................................................................................................7 4.2 Cold and Hot Safe Work Permits .........................................................................10 4.3 Safe Work Permit from Completion ......................................................................11 4.4 Pre-Job Hazard Assessments ..............................................................................12 4.5 Confined Space Entry...........................................................................................14 4.6 Ground Disturbance .............................................................................................15 4.7 Fall Protection Rescue Plan .................................................................................15 4.8 Term Safe Work Agreements ...............................................................................16 4.9 Emergency Conditions .........................................................................................16 5. References .......................................................................................................................17 6. Definitions ........................................................................................................................17 CURRENT VERSIONS OF APPROVED DOCUMENTS ARE MAINTAINED ONLINE. PRINTED COPIES ARE UNCONTROLLED.
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North America Onshore
EH&S Practice
Safe Work Permits
1.
Number:
P103
Purpose
The purpose of this Practice is to ensure accurate, effective and consistent application of
Safe Work Permits, Term Work Safe Agreements and Hazard Assessments to assess risks,
identify the hazards and initiate controls to manage those hazards for the assigned tasks.
Safe Work Permits and Term Safe Work Agreements allow the Operating Authority the
opportunity to communicate potential hazards the Performing Authority may be exposed to.
Pre-Job Hazard Assessments provide an opportunity for the Performing Authority to identify
potential hazards at the worksite. The application of the documents within this Practice will
minimize the possibility of loss to people, environment and equipment.
EH&S Practices provide interpretation of regulations, standards, and Industry recommended
Practices (IRPs) and any additional Suncor requirements. All North America Onshore
Business Areas are required to develop their own procedures to implement this Practice as
required.
Appendices A to D provide supporting information.
2.
Scope
2.1 This Practice applies at all Suncor Energy North America Onshore worksites and applies
to Suncor workers and contractor personnel. References in this document to “Suncor
Personnel” include directors, officers, employees, contract workers, consultants and
agents of Suncor.
2.2 Where a site specific procedure has been written that follows the minimum components
of, and meets the intent of the criteria in this Practice, it shall take precedence over
specific requirements herein.
a) Appendix A provides Suncor’s Safe Work Permit (North America Onshore)
standard form. This Practice applies specifically to the following:
b) Cold Safe Work Permits– Work with no ignition sources within classified areas
(i.e., housekeeping and inspections).
c) Hot Safe Work Permits– Work where ignition sources will be intentionally
introduced or anticipated within classified areas (i.e., welding and vehicle entry).
d) Term Safe Work Agreements (Appendix B) – Work is low complexity, low risk,
long duration and is impractical to issue other permits each time a task is
undertaken (i.e., product fluid hauling and road/lease/site maintenance).
e) Pre-Job Hazard Assessments (Appendix C) – Recognizes potential hazards at
the worksite and allows for the identification of equipment, processes, and
materials to control the anticipated hazards.
2.3 Deviations from this Practice must have a risk assessment performed and be approved
by the Vice President of the North America Onshore Business Area.
3.
Responsibilities
The following individuals and groups have the defined responsibilities:
3.1
Site Supervisor
The Site Supervisor’s specific Safe Work Permit/Term Work Safe Agreement
responsibilities are:
a) Administer this Practice including implementation, training, compliance, auditing and
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North America Onshore
EH&S Practice
Safe Work Permits
Number:
P103
monitoring.
b) Ensure persons who sign Safe Work Permit as Operating Authority have completed
Safe Work Permit, Confined Space Entry (P301), Ground Disturbance (P302) and
Fall Protection (P314) Practices knowledge checks and this Practice are reviewed
every three years.
c)
Review the Term Safe Work Agreement (Appendix B) to ensure that all requirements
have been considered and issue in consultation with the respective EH&S Advisor.
d) Identify training requirements and ensure all required training identified on the Term
Safe Work Agreement is maintained.
e) Ensure the duration of the Term Safe Work Agreement must not exceed two years
but the terms of the agreement must be reviewed annually.
f)
Ensure a copy of the Term Safe Work Agreement is immediately available to
workers and the Contractor’s employees while on Suncor worksites.
g) Monitor contractor compliance to the Term Safe Work Agreement by performing field
spot checks of the Contractor activities.
h) Aware of all potential hazards associated with the work to be done.
3.2
i)
Familiar with all procedures and precautions required to perform the work safely and
must understand the importance of ensuring that these conditions are followed.
j)
Competent with all atmospheric testing equipment and procedures.
Operating Authority
The Operating Authority is the person having immediate responsibility for the operations
affected by the specific Safe Work Permit. The Operating Authority must have direct
control of the worksite and has the following responsibilities:
a) Issue appropriate Safe Work Permits as per the decision chart.
b) Identify all potential hazards and the necessary controls for the work being
performed.
c) Identify those areas that Performing Authority agrees to take responsibility for on the
Safe Work Permit and makes sure Performing Authority initials appropriately.
d) Ensure that all conditions are acceptable, completely understood and agreed to by
the Performing Authority.
e) Ensure atmospheric tester, safety watch and /fire watch are competent for their
assigned task.
f)
Ensure the appropriate critical / routine safe work procedures are provided to the
Performing Authority and identified on the Safe Work Permit.
g) Ensure atmospheric testing is completed as required.
h) Inform next shift of permits still in effect.
i)
Ensure that “Hand Back” is completed, signed and the agreements are properly filed.
j)
Ensure the Performing Authority is competent in the adequate and effective
completion of Pre-Job Hazard Assessments.
k) Be familiar with all procedures and precautions required to perform the work safely
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EH&S Practice
Safe Work Permits
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P103
and must understand the importance of ensuring that these conditions are followed.
l)
Aware of all potential hazards associated with the work to be done.
m) Competent with all atmospheric testing equipment and procedures.
n) Be responsible for any updates or changes to this Practice.
3.3
Performing Authority
The Performing Authority is the person supervising or conducting the work specified in
the Safe Work Permit/Agreement. Common titles are crew leader, job foreman, craftsman
and worker. The Performing Authority responsibilities are below:
a) Ensure that workers are properly trained or supervised.
b) Assist in completion of the Safe Work Permit/Agreements.
c) Ensure that all conditions and terms are acceptable and that any responsibilities
identified on the agreement are completely understood and initialled to indicate
understanding.
d) Instruct all workers covered under this agreement of their responsibilities regarding
the identified hazards and controls.
e) Ensure “Hand Back” is completed and signed as specified in the Safe Work
Agreement.
f)
Complete the hazard assessment upon arriving at site/location on the back side of
white Safe Work Permit copy.
g) Instruct all workers covered under the Safe Work Permit/Agreement as to their
responsibilities regarding the hazards and controls identified.
h) Aware of their responsibilities required by this Practice.
i)
3.4
Competent in their assigned task. (This may require safety training such as, but not
limited to, Confined Space Entry, Ground Disturbance, Fall Protection, WHMIS, H2S
Alive, TDG, Respiratory Fit-testing and training for the respiratory apparatus used onsite).
Gas Atmosphere Tester
A Gas/Atmosphere Tester is the individual assigned responsibility to conduct hazardous
atmosphere monitoring. The Gas/Atmosphere Tester responsibilities are:
a) Monitor controls for atmospheric hazards occur as stipulated in the Safe Work
Permit/Agreement.
b) Perform appropriate gas/atmosphere testing recording and sign off at the required
times as specified by the Safe Work Permit/Agreement.
c) Ensure personal monitors are used at all times, however if workers are leaving the
location for any period of time (lunch, coffee, tool run) the results of the monitoring
must be documented on the Safe Permit/Agreement.
d) Competent with all atmospheric testing equipment and procedures.
e) Be familiar with following:
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Safe Work Permits
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i. Work location;
ii. Associated hazards; and
iii. Required procedures and precautions.
3.5
Safety Watch
a) Monitor the work in progress to ensure all workers are immediately alerted to
hazardous conditions.
b) Initiate rescue if hazardous conditions develop.
c) They must not be assigned any responsibilities that interfere with the ability to
monitor the task at hand.
d) Competent to initiate applicable rescue procedures, under some circumstances be
required to have the skill of a rescue responder.
e) Be familiar with following:
i. Work being performed;
ii. Configuration of the work area; and
iii. Potential hazards and precautions
Required Safety Watch Training
a) In possession of a valid First Aid Certificate unless a rescue team will be used has
the required Safety Watch training.
b) Note: A Safety Watch may also be a Fire Watch providing they meet the
qualifications.
3.6
Fire Watch
A Fire Watch is the individual assigned responsibility to watch for indications of fire,
smoke or other hazardous conditions in an area defined by both the Operating and
Performing Authorities. The Fire Watch responsibilities are:
a) Ensure that their primary focus is the hot work in progress.
b) Initiate or effect emergency response procedures in the case of fire.
c) Be familiar with following:
i. Work being performed;
ii. Configuration of the work area; and
iii. Site Method for escalating site fire alarm.
Required Fire Watch Training
a) Have completed a fire training course using the equipment that will be used for
response and the required Fire Watch training.
3.7
Rescue Team
The Rescue Team must be of sufficient size, properly equipped and trained to effectively
respond to a rescue. The following qualifications must be considered for the
Rescue Team:
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North America Onshore
EH&S Practice
Safe Work Permits
Number:
P103
a) Physically capable and competent to perform rescue procedures.
b) In possession of a valid H2S Alive certificate if H2S may be encountered.
c) In possession of a valid First Aid / CPR certificate.
d) Fit-tested and trained in use of available respiratory equipment.
e) Certified in high angle rescue.
f) Familiar with the work being performed.
g) Familiar with the configuration of the confined space if applicable.
h) Competent in Confined Space Entry (see Suncor Confined Space Entry [P301]).
3.8
Contractors
For the purposes of Term Agreements, the Contractor is responsible for the following:
a) Ensure that staff is knowledgeable in the content and application of the Term Safe
Work Agreement.
b) Ensure compliance with provincial Occupational Health and Safety legislation; any
Suncor Safe Work Practices and Procedures, and other regulations pertaining to the
work being done.
c) Review the Term Safe Work Agreement with its employees and ensure the
appropriate employees sign the Agreement
d) Provide the Site Supervisor with a copy of the current Term Safe Work Agreement
that includes the signatures of all orientated and qualified employees.
4.
4.1
Requirements
Administration
4.1.1 The Safe Work Permit Decision Chart (Figure 1) shall be used to identify the
required Safe Work Permits and agreements. Once the required permit and/or
agreement is identified, the details for each of these can be found in the following
corresponding appendices:
Appendix A – Suncor North America Onshore Safe Work Permit form
Appendix B – Term Safe Work Agreements
Appendix C – Pre-Job Hazard Assessments
4.1.2 Distribution
a) All Safe Work Permits have three copies, white copy (Performing Authority,
yellow copy (Operating Authority) and a pink copy (optional).
b) The Operating Authority will complete the Safe Work Permits and sign off on
the bottom. The Performing Authority will address his responsibilities and sign
off on the bottom.
c) The Performing Authority is given the white copy and is required to fill out the
hazard assessment on backside of the white copy upon arriving at task
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Figure 1
E N E R G Y
Issue Fall
Protection
Rescue
Plan
Is
Fall Protection
Required
Issue Cold Safe Work
Permit and complete
documented Pre-Job
Hazard Assessment at
location of task
Confined
Space
Area?
Restricted, Low,
Medium High.
Issue Cold Safe Work
Permit and complete
documented Pre-Job
Hazard Assessment at
location of task
Issue Hot Safe Work
Permit and complete
documented Pre-Job
Hazard Assessment at
location of task
Confined
Space
Area?
Restricted, Low,
Medium High.
Issue Hot Safe Work
Permit and complete
documented Pre-Job
Hazard Assessment at
location of task
Can A term
agreement be set
up for this task
with Contractor.
Yes
Create Term
Agreement
Term Agreement (Low Risk)
No
North America Onshore
EH&S Practice
Safe Work Permits
Number:
P103
destination. The Operating Authority retains the yellow copy.
d) If the Performing Authority (Foreman) that is signed onto the Safe Work Permit
is required to leave location and work continues, the Safe Work Permit is to
stay at location and all Performing Authority responsibilities are reviewed with
and assigned to a single competent Performing Authority member.
e) Upon completion of work both Performing and Operating authorities sign off on
the hand back section and both the white and yellow copies are to be filed
together following the records management procedures outlined in this
Practice. The pink copy is optional and can be given to the Performing
Authority for their records.
f)
Hand back completion of the Safe Work Permit may be phoned in to the
Operating Authority due to different circumstances (after hours, geographical
location) however the white copy is required to be filed with the yellow copy in
the filing system. An agreed upon method of receiving the white copy should
be discussed.
g) All attachments (Confined Space, Ground Disturbance, Fall Protection Rescue
Plan) are to be affixed to the white Safe Work Permit copy and filed according
to records management procedures outlined in Section 4.1.2 of this Practice.
Term agreements upon completion will be stored electronically with all
signatures. It can be printed in the event a new worker is added to the
agreement. Paper copy with all signatures can also be stored for ease of
Operating Authority accessibility.
4.1.3 Records Management
Records of Safe Work Permits/Agreements shall be maintained as follows:
Cold/Hot Safe Work Permit
3 months minimum
Term Safe Work Agreement
3 months after expiry
1
Confined Space Entry Attachment and applicable Safe
Work Permits
2 years minimum
Ground Disturbance Attachment2 and applicable Safe Work
Permits
1 year minimum
Fall Protection Rescue Plan2 and applicable Safe Work
Permits
1 year minimum
Monitoring and Auditing records
2 years minimum
Competency Checks (paper or electronic)
3 years minimum
1
Occupational Safety and Health Law minimum requirements for Confined Space Entry records. These
Confined Space Entry Attachments and corresponding Safe Work Permits shall have their own file at
each site; separate from the other Safe Work Permit records.
2
Ground Disturbance Attachments and Fall Protection Rescue Plans along with their corresponding Safe
Work Permits should have their own file at each site; separate from the other Safe Work Permit records.
4.1.4 Safe Work Permit Evaluation
a) Overall compliance to the Safe Work Permit System shall be initiated by
completing a Safe Work Permit evaluation (Appendix D). The evaluation will
determine whether improvement opportunities are required.
b) Safe Work Permit evaluations must be completed after the booklets are
finished or more often if there are compliance issues. Appendix D provides a
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North America Onshore
EH&S Practice
Safe Work Permits
Number:
P103
copy of the evaluation form.
c) Only the Performing Authority (White Copy) shall be evaluated since the White
Copy has all the appropriate information to be evaluated.
d) Site Supervisors and or the Operating Authorities must conduct Safe Work
Permit Evaluations by using the following processes:
4.2
i.
Select three completed Safe Work Permit (White Copy) and fill out
evaluation.
ii.
Review the all sections of the Safe Work Permit to determine if they are
filled out properly or if improvement is needed.
iii.
Circle NI (needs improvement) Yes/No and provide comment for Yes
findings.
iv.
If a section of the evaluation form does not apply to the SWP being
evaluated, indicate it’s NA (not applicable).
v.
Enter all evaluations into an Incident Learning and Prevention (ILP)
entry.
vi.
Include improvement opportunities identified in the evaluation process as
a remedial action as an incident learning and prevention (ILP) entry for
follow up.
vii.
Upon completion of a planned event entry into the ILP system attach
copies of the evaluated Safe Work Permit to the evaluation form and
forward to EH&S Advisor.
Cold and Hot Safe Work Permits
4.2.1 A Cold and Hot Safe Work Permit must be issued by competent Worker who is
familiar with the work or situation and under his or her control.
4.2.2 A Safe Work Permit may extend over a shift change and/or an extension time may
be given to the Safe Work Permit should the job take longer than originally
determined provided it must not exceed 24 hours and for the following
circumstances:
a) Conditions under which the original Safe Work Permit was issued have not
changed;
b) Operating Authorities involved in shift change review the Safe Work Permit and
agree on conditions of work; and
c) Operating Authority arriving on shift must also sign the Safe Work Permit
confirming approval.
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North America Onshore
EH&S Practice
Safe Work Permits
Number:
P103
4.2.3 All Safe Work Permits must specify the physical boundaries of the work. These
boundaries will limit the Performing Authority and workers from being exposed to
conditions in areas not considered by the Operating Authority.
4.2.4 More than one location may be identified on the Safe Work Permit providing the
work being done and the conditions that will be encountered are the same at each
location identified on the Agreement. Although multiple locations can be added to a
Safe Work Permit, Pre-Job Hazard Assessments (R.I.C.E card) are required to be
completed for every location.
4.2.5 “Critical/High Risk” tasks must have work procedures for the performing personnel
to follow. The corresponding procedure and number will be identified and/or
attached on the Safe Work Permit.
4.3
Safe Work Permit from Completion
A copy of Suncor North America Onshore’ standard Safe Work Permit form is found in
Appendix A.
4.3.1 Location
a) Ensure the location and description of work is adequately defined.
b) Identify name of the company performing the work.
c) Consider worker orientation requirements.
d) Consider vehicle entry requirements.
e) Specify permit duration (not to exceed 24 hours).
f) Consider Management of Change and ensure all sections are complete.
4.3.2 Equipment Safety/Hazard Check
a) Ensure all equipment safety hazard checks have been evaluated and when
required initialled by the appropriate party.
b) Identify any other equipment or safety/hazard considerations not included on
the checklist.
4.3.3 Special Requirements
a) Check off all special requirements applicable to the task.
b) Identify special protective equipment.
c) Provide or review the procedures applicable to the assigned task.
d) Identify other environmental or safety considerations not included on the
checklist.
4.3.4 Hot Work Considerations
a) Ensure all types of hot work are considered and check off when applicable.
b) Identify all ignition sources associated with the task
4.3.5 Hot Work Requirements
a) Ensure all applicable hot work requirements have been evaluated and when
required initialled by the appropriate party.
b) Identify safety equipment and precautions necessary to reduce the risk of the
hot work.
4.3.6 Confined Space Entry
a) Refer to the “Confined Space Entry Decision Tree” or “Definitions” in this
Practice when required.
b) Ensure the Part I is complete (planning the CSE).
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North America Onshore
EH&S Practice
Safe Work Permits
Number:
P103
c) Ensure the Part II is complete (pre-entry meeting).
4.3.7 Ground Disturbance
a) Complete and attach the “Ground Disturbance Attachment” when the
disturbance is greater than 30 cm or any removal of cover over a pipeline.
b) Ensure the Part I is complete (planning the ground disturbance).
c) Ensure the Part II is complete (pre-job meeting).
4.3.8 Fall Protection
a) Ensure a Fall Protection Rescue Plan is completed when required.
b) Refer to the “Fall Protection Decision Tree” in the Fall Protection Practice
(P314) when required.
4.3.9 Atmospheric Testing
a) Trained workers must perform atmospheric testing at specific intervals using
appropriate equipment.
b) Identify appropriate retest frequency tested against duration of job.
c) Ensure workers assigned this task are trained/competent.
d) Ensure gas test monitor is calibrated and bump tested.
e) Identify all special instructions.
f) Record all equipment that is issued for the task.
g) Identify all emergency response considerations.
4.3.10 Operating and Performing (signatures required)
a) Because the Safe Work Permit is a joint agreement between the Operating and
Performing Authorities, both parties must sign the Safe Work Permit, indicating
they have jointly taken part in the Permit’s development, and agree with what
the permit states and requires.
4.4
Pre-Job Hazard Assessments
4.4.1 A Pre-Job Hazard Assessment recognizes potential hazards at the worksite and
allows for the identification of equipment, processes, and materials to control the
anticipated hazards. A Pre-Job Hazard Assessment must be completed for all
tasks. It must be conducted at worksite upon arrival at work location and assessed
for the following conditions:
a)
b)
c)
d)
A new work process is introduced;
A work process or operation changes;
Before construction or significant changes or alterations to a worksite; or
At appropriate interval to ensure hazards do not develop.
4.4.2 The Pre-Job Hazard Assessment can be found on the back page of the white Safe
Work Permit Copy (Appendix C). Stand alone copies (RICE Card) are also
available.
4.4.3 Figure 2 provides a decision flow chart to assist the Operating Authority on when
and who is required to complete a Pre-Job Hazard Assessment for the task the
Operating and Performing Authorities are performing. If the Performing Authority is
limited in his/her experience to Suncor’s Pre-Job Hazard Assessment, the
Operating Authority must participate in its completion.
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Operations Permitting Hazard Assessment Decision
Flowchart
Does the task (work) involve anyone from the maintenance
department (I&E, Mechanic, Labour Crew) or Contract
services
Worker has documented operator duty
competency completed and is deemed capable of
operating piece of equipment related to this task
YES
No
No
Is the task you are performing
your daily rounds
YES
No
No
Task is being completed as part of the Suncor Contractor
Term agreement. The worker has signed off on agreement
and initial pre-job hazard assessment has been completed
on workers first visit
YES
YES
Will task impact other work
YES
Complete Safe Work
Permit and
documented Pre-Job
Hazard Assessment.
Assessment must be
completed at location
of task (permit writer
must participate in
assessment)
No
Does the Task you are
performing include breaking
integrity
Add ProAct entry
to eliminate or
reduce potential
risk
YES
YES
No
Does the task you are performing
include the maintenance/
commissioning of rotating
equipment
Perform a
documented
Pre-Job
Hazard
Assessment at
location of task
YES
No
Is there a potential for a
exposure to Chemical,
Mechanical, Thermal, Biological
type hazards.
No
YES
No
The task involves the transfer or
decanting of fluid
No
Can Hazard be
eliminated or risk
reduced by worker
intervention
YES
No Documented
Hazard Assessment
required
Continue to
identify hazard on
pre-job hazard
assessment and
initiate effective
controls
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EH&S Practice
Safe Work Permits
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P103
4.4.4 One Safe Work Permit may be used for similar tasks at different locations; however
a Pre-Job Hazard Assessment must be completed for each and every task at the
different locations.
4.4.5 Workers must only check off the potential hazards at the worksite for the task they
are performing. All the controls that are required for the potential hazards that are
checked off must be added and used to control the potential hazard.
4.4.6 If additional workers arrive at site after the commencement of the task, work is to
stop and new workers review and sign off on the Pre-Job Hazard Assessment.
4.4.7 A Pre-Job Hazard Assessment recognizes potential hazards at the worksite and
allows for the identification of equipment, processes, and materials to control the
anticipated hazards. A Pre-Job Hazard Assessment must be completed for all
tasks. It must be conducted at worksite upon arrival at work location for the
following conditions:
a)
b)
c)
d)
4.5
A new work process is introduced;
A work process or operation changes;
Before construction or significant changes or alterations to a worksite; or
At appropriate interval to ensure hazards do not develop.
Confined Space Entry
4.5.1 The Suncor Confined Space Entry Practice (P301) must be consulted when a
Confined Space Attachment is required.
4.5.2 The Confined Space Attachment is a two part attachment to either a Cold/Hot Safe
Work Permit. It outlines the additional precautions required for entry into confined
spaces that are classified as 3.2 (Medium) Risk and 3.3 (High Risk) in the Suncor
Confined Space Entry Practice (P301).
a) Part I of the Attachment outlines the requirements for a Pre-Job Planning
meeting where all the following must be identified along with the appropriate
control measures:
i. Hazards;
ii. Cleaning needs; and
iii. Isolation methods.
b) Part II of the Attachment outlines the requirement for a pre-entry meeting that
must be conducted with all Workers immediately prior to the entry. At this
meeting, all requirements of the Safe Work Permit, the Pre-Planning meeting,
as well as those of the Emergency Rescue and Communication Plans must be
reviewed. Examples of common confined spaces include:
i.
ii.
iii.
iv.
v.
vi.
Vessels
Towers
Fireboxes
Sewers
Sewer man-ways
Pits
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vii.
viii.
ix.
x.
4.6
Number:
P103
Sumps
Storage tanks
Trenches
Cellar
Ground Disturbance
4.6.1 For any disturbances of the earth exceeding 30 cm in depth or any removal of
initial ground cover over a pipeline, a Ground Disturbance Attachment must be
completed. Examples of Ground Disturbance include:
a) Pile driving
b) Auguring
c) Excavation
d) Rat holing
e) Ripping
f) Trenching
4.6.2 A Ground Disturbance Attachment is a two-part attachment to either a Cold/Hot
Safe Work Permit that outlines the additional precautions required for ground
disturbance.
a) Part I of the Attachment outlines the requirements for a pre-job planning
meeting where all hazards and stakeholders must be identified along with the
appropriate control measures.
b) Part II of the Attachment outlines the requirement for a pre-job meeting that
must be attended by the:
i. Operating Authority;
ii. Performing Authority;
iii. Ground disturbance representative; and
iv. All Workers involved in the ground disturbance.
4.6.3 At the pre-job meeting, all requirements of the Safe Work Permit and all items
within the pre-planning meeting must be reviewed.
4.6.4 Refer to the Suncor Ground Disturbance Practice (P302) when a Ground
Disturbance Attachment is required
4.7
Fall Protection Rescue Plan
4.7.1 A written Fall Protection Rescue Plan is required as part of the risk assessment or
task analysis for the job when working at heights in excess of 3 m (10 ft) or where
there is the possibility of unusual risk of injury if a worker falls from any height. It is
required to ensure the following:
a) A fall protection system or equipment has been properly identified and selected
for working at those heights;
b) Fall hazards from those listed on the Fall Prevention Flow Chart (Page 6 of the
Suncor Fall Protection Practice [P314]) have been identified; and
c) A Safe Work Permit and the Fall Protection Rescue Plan have been properly
completed and are in place.
A blank copy of the Fall Protection Plan “Attachment A” can be found in the Suncor
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Fall Protection Practice (P314).
4.7.2 Workers must ensure that a Fall Protection Rescue Plan is documented and in
place prior to the commencement of work, as per OH&S code requirement.
4.7.3 The Fall Protection Rescue Plan must be reviewed, each item discussed to reach
agreement and responsibility established at this meeting.
4.7.4 The Performing Authority or person in charge of the job must conduct a Pre-Job
Hazard Assessment meeting with all workers involved.
4.8
Term Safe Work Agreements
4.8.1 Mobile equipment requirements in Term Agreement take into account applicable
considerations of Cold/Hot/ Safe Work Permit including a requirement for
competent workers.
It will also identify best safe work practices that will reduce the likelihood of injury,
spills or other losses when it is impractical to issue a Cold/Hot/ Safe Work Permit
each time the task is performed.
4.8.2 A Term Safe Work Agreement is a written agreement between Suncor and
selected contractors for low complexity, low risk, and longer duration work and is
used to identify:
a)
b)
c)
d)
Potential hazards within the workplace
Pre-requisite worker training needs
PPE required
Emergency information
4.8.3 Duration of Term Safe Work Agreements must not exceed two years but the
terms of the agreement must be reviewed annually.
4.8.4 A Term Safe Work Agreement must specify the location and nature of the work to
be done in detailed description. Failure to follow the detailed description will void
Term agreement and Safe Work Permits will be used to control the contractors
work direction.
4.8.5 Specific work procedures that are identified on the Term Agreement must be made
available for the Performing Authority’s reference and shall be reviewed with all
applicable parties as a Term Agreement requirement
4.8.6 The Site Supervisor may add to or modify the Term Safe Work Agreement
requirements; however, relaxing any of the specified requirements must be done in
consultation with the area EH&S Advisor.
4.9
Emergency Conditions
4.9.1 Emergency during Safe Work Permit Work
a)Any emergency will automatically suspend all Safe Work Permits and
attachments.
b)The Operating Authority and Performing Authority must evaluate the terms and
conditions for the:
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i. Continuation of the work; or,
ii. Re-issue of a new Safe Work Permit.
4.9.2 Emergency Conditions Requiring Immediate Work
a) If there is an emergency at a facility and work must be carried out to deal with
the emergency, the work can precede without formal Safe Work Permits. All
safe work practices and policies must still be followed and adhered too.
b) Emergency Response Plans must be in place which contains procedures to
control all types of emergencies. The training of those who may be involved in
special duties is identified in these plans.
5.
References
Suncor Energy Inc.
Confined Space Entry Practice (P301)
Ground Disturbance Practice (P302)
Fall Protection Practice (P314)
Provincial Regulations
Alberta Occupational Health and Safety Act Sect. 1, 2.1, 2.2, 26.
Alberta General Safety Regulations - Code for Electrical Installations at Oil and Gas Facilities
(classifications) Sections 14.3, 15, 185, 187, 188, 189, 190, 191
Saskatchewan Occupational Health and Safety Act Sections 3, 4.
Saskatchewan General Safety Regulations Part II, Sections 5, 6, 14, 15 and Part XIV,
Sections 140, 191
BC Occupational Health and Safety Regulation Sect 3
6.
Definitions
The following terms are used in this Practice:
Classified Area
(As per the CSA C22.1 Safety Standard for Electrical Installations,
Canadian Electrical Code Part 1, Section 18-004).
Class I – Locations are those in which flammable gasses or
vapours are or may be present in the air in quantities sufficient to
produce explosive or ignitable mixtures.
Class II – Locations are those which are hazardous because of the
presence of combustible or electrically conductive dusts.
Class III – Locations are those which are hazardous because of the
presence of easily ignitable fibres of flyings but in which such fibres
or flyings are not likely to be in suspension in air in quantities
sufficient to produce ignitable.
Cold Safe Work
Permit
A written agreement between the Operating Authority and the
Performing Authority requires consideration of all recognized
potential hazards and outlines the conditions under which the work
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can be conducted with minimum risk.
Competent Worker
An adequately qualified and suitable trained person with sufficient
experience to safely perform work without supervision or with only a
minimal degree of supervision.
Confined Space
An enclosed or partially enclosed space large enough for a person
to enter to perform assigned tasks which, is not designed or
intended for continuous human occupancy, may become
hazardous to a person entering it because of the contents, design,
work activity or may have restricted access and egress hindering
the provision for first aid, rescue or other emergency services.
Confined Space
Classification
3.1 – Low Risk: A confined space in which there does not exist and
is not likely to exist, a hazardous gas, vapour, dust or fumes;
and/or, an oxygen content less than 19.5% or more than 23% by
volume.
3.2 – Medium Risk: A confined space in which there has existed or
was likely to exist, a hazardous gas, vapour, dust or fumes and/or,
an oxygen content less than 19.5% or more than 23% by volume.
WHICH HAS BEEN PURGED, VENTILATED AND STEPS TAKEN
TO PROVIDE AND MAINTAIN A NON-IDLH Atmosphere.
3.3 – High Risk: A confined space in which there now exists, a
hazardous gas, vapour, dust or fumes and/or, oxygen content less
than 19.5% or more than 23% by volume.
Continuous Monitor
A device, series of devices or combination of devices arranged
around the perimeter of the work site, that will alarm the workers in
advance of any contaminant or hazardous gas reaching the
workers location. The arrangement shall be in such a manner that
the worker or workers have adequate time to shut down, exit or
make secure the work site. Continuous Monitors shall be tested
daily and maintained in accordance with manufacturer’s
recommendations. The installation and use of Continuous Monitors,
does NOT preclude the need for a properly maintained and tested
Personal Monitor. Examples are: gas testing the confined space
while a worker is performing work in that confined space, piping
modification inside the plant with welding required.
Contractor
A person, partnership or group of persons who, through a contract,
an agreement or ownership, directs the activities of one or more
employers involved in work at a worksite.
Fall Protection
Rescue Plan
A written Plan is required as part of the risk assessment or task
analysis for the job when working at heights in excess of 1.2 m (4
ft) from a permanent work platform or 3 m (10 ft) from a temporary
work area. Refer to the Suncor Fall Protection Practice (P314) for
more details.
Ground Disturbance
For any disturbances of the earth exceeding 30 cm in depth or any
removal of initial ground cover over a pipeline, a Ground
Disturbance Attachment must be completed. Refer to the Suncor
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Ground Disturbance Practice (P302) for more details.
Ground Disturbance
Attachment
A two-part attachment to either a Cold/Hot Safe Work Permit that
outlines the additional precautions required for ground disturbance.
High Risk / Loss
Potential
Working around equipment where the potential for loss is greater
then normal, or where the severity of loss, should it occur, could be
serious or fatal. Considerations are: the work history of loss,
frequency of work, competency of the workers involved, duration of
work, and the potential severity of any loss. Examples of this are:
confined space entry, hot work, man basket work, hot tapping,
breaking piping integrity, working around equipment with lethal
levels of H2S or other toxic substances, decanting of hydrocarbon.
Hot Safe Work
Permit
An agreement that includes all conditions listed on the Cold Safe
Work Permit and includes consideration of ignition sources present
or introduced in classified areas. These precautions are necessary
to minimize the risk of fire or explosion.
Ignition Source
A hazard with a potential source of ignition such as
arching/sparking of electrical equipment components, fired heater
burners, internal combustion engines (vehicles), hot work activities
(welding, cutting, drilling, grinding, chipping), lightning, pyrophoric
(iron sulphide) deposits and electrostatic discharges from moving
liquids, non-conductive material (plastic pails), clothing and the
human body in any flammable or explosive environment.
MSDS (Material
Safety Data Sheet)
A form that provides data about a particular substance. It is
intended to provide workers and emergency personnel with
procedures for working and handling the substance in a safe
manner and includes information such as physical data (melting,
boiling and flash point), toxicity, health effects, first aid, readability,
storage, disposal, protective equipment and spill handling
procedures.
Operating Authority
The person having immediate responsibility for the operations
affected by the specific Safe Work Permit. The Operating Authority
must have direct control of the worksite.
Operator Preparation
Work required preparing the site, such as isolation of equipment,
depressurization, purging venting or anything that requires an
operator’s specific knowledge of that facility or task. Preparation
may be performed by the Performing Authority if they have specific
knowledge of the facility and task.
Performing Authority
The person supervising or conducting the work specified in the
Safe Work Permit. Common titles are crew leader, job foreman,
craftsman and worker.
PPE (Personal
Protective
Equipment)
Equipment or clothing worn by a worker for protection against
health or safety hazards associated with the working conditions at a
worksite. Standard PPE is not specified in the Safe Work Permit but
will include; approved safety Footwear, Fire Resistant Clothing
outer layer, Safety Eyeglasses, Hard Hat, Gloves, Non-fusible
thermal insulating layer appropriate for the season or working
conditions. Special PPE and training will need to be considered
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when controlling hazards like Benzene, H2S, NORMs, Confined
Spaces, and Fall Hazards.
Respiratory
Guideline
The purpose is to ensure that where respiratory protection is
necessary, the proper type of respirator is correctly employed to
achieve full protection of workers' health.
Safe Guards
A device or system intended to protect personnel, equipment or the
environment from harm. Examples of common workplace
safeguards include instrumentation control systems, interlocks,
pressure relief devices.
Safe Work Permit
An agreement between the Operating Authority and the Performing
Authority and be any of the following Cold, Hot, and Term Safe
Work Agreements.
Shift
A person's scheduled period of work, esp. the portion of the day
scheduled as a day's work when a shop, service, office, or industry
operates continuously during both the day and night.
Term Agreement
A Term Safe Work Agreement will best safe work practices that will
reduce the likelihood of injury, spills or other losses when it is
impractical to issue a Cold/Hot/Verbal Safe Work Agreement each
time the task is performed.
Worker
A person engaged in an occupation.
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APPENDIX A – SUNCOR NORTH AMERICA ONSHORE SAFE WORK PERMIT
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PAGE 21 OF 30
Safe Work Permit
(Natural Gas)
000000
E N E R G Y
NI
Y
N
Initials
(it is the responsibility of the workers identified below to ensure effective
controls are documented and in place for the hazard (s) identified)
Oper
Oper
Craft
N/A
Craft
N/A
Initial
Initial
Chemical Hazard Precaution
Control of Hazardous Energy Required
NI
Y
N
Arc Flash Consideration
Personal Gas Monitor bump tested
Other Safeguards bypassed
Special Requirements
Critical Defeat Required
Barricades / signs
Safety watch
Procedure Available
Benzene PPE
Spill Containment
Critical Task Procedure Number
Procedure Required
NI
Y
N
Ground Disturbance attachment number
If yes, complete and review applicable attachments
If yes, complete and review Fall Protection / Rescue Plan
If yes, complete and review Ground Disturbance Attachment.
Directing or containing Sparks
Continuous Gas Monitoring
NI
Y
N
Atmospheric Testing
Time of day
O2
%
LEL
%
H2S
PPM
Toxic substance
being tested
Toxic
Substance
Concentration
(PPM or %)
Testers Signature
NI
Y
N
Emergency Contact
NI
Y
N
14107 (09/03)
The DATA Group of Companies (403) 272-7440
S6029143.AI-M
North America Onshore
EH&S Practice
Safe Work Permits
Number:
P103
APPENDIX B – TERM SAFE WORK AGREEMENT
A Term Safe Work Agreement is a written agreement between Suncor Energy Inc. (Suncor) and the
selected Contractor. Term agreements are to be used where the task being performed is limited in its
complexity, is low risk, and is completed frequently. Term agreement must identify required training
for the tasks being performed and potential hazards workers may be exposed to and required to be
prepared in the event of an emergency. Term agreements will explain (description) in detail the task
to be performed as part of the agreement.
Contractors are to follow Suncor’s practice, policies and standards unless specified different in the
term agreement.
Any work that is being performed outside of the agreed upon task description will require an issued
Safe Work Permit.
All tasks require a Pre-Job Hazard Assessment to be completed at each location work is being
performed. The Pre-Job Hazard Assessment Appendix “A” must be used for all tasks unless the
contractor’s Pre-Job Hazard Assessment has been approved by Suncor’s EH&S Department.
CONDITIONS
1.
The Site Supervisor must ensure all requirements of this Term Safe Work Agreement are met
prior to commencement of work.
2.
The Site Supervisor must identify who will provide the training and equipment required, and
makes appropriate arrangements with the contractor in order to avoid confusion later regarding
costs and equipment.
3.
Every worker must be properly trained and shall have signed the Term Safe Work Agreement
prior to commencement of work. Failing this, an appropriate Safe Work Agreement must be
issued.
4.
All workers signing this agreement must be knowledgeable of applicable Suncor Energy
Practices / Guidelines and Provincial Occupational Health and Safety Regulations pertaining to
the work being done.
5.
All workers signing this agreement must be knowledgeable in applicable procedures for the
task they are performing. All required procedures must accompany, and be reference in the
Term Safe Work Agreement.
6.
Work being performed must cease if:
–
Emergency alarms are activated
Conditions in area become hazardous
Requested to cease work by appropriate authorities
7.
It is the responsibility of the Contractor to arrive with equipment in good working order and able
to produce inspection and certification records for the equipment being used”.
DESCRIPTION OF TASK
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Hazard Identification and Controls
Identify potential hazard, identify responsible person add controls for identified hazards.
These are the hazards Suncor Energy recognizes as potential Hazards.
Potential Hazard
OPER
CONT
N/A
Controls in Place
CHEMICAL EXPOSUREMSDS REQUIRED
LEL EXPOSURE
H2S EXPOSURE
OXYGEN DEFICIENCY
WORKING AT HEIGHTS
CONTROL OF HAZARDOUS ENERGY
ARC FLASH CONSIDERATIONS
GROUNDING NECESSARY
ENTERING A CLASSIFIED AREA (25’)
IMPACT ON OTHER WORK
SAFETY SYSTEMS REQUIRE BYPASS
CELL PHONE, PAGER RESTRICTIONS
POWER TOOL USAGE
WORKING ALONE CONSIDERATIONS
SPILL CONTAINMENT
POSITIVE AIR SHUT OFF
SAFETY WATCH REQUIRED
HOT WORK REQUIRED
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Training Required
Identify required training and responsible person or party to deliver.
Required Training
OPER
3rd party
N/A
Comments
FIRST AID
H2S ALIVE
TDG
WHMIS
WORKING AT HEIGHTS
FIT TESTED
CONFINED SPACE ENTRY
GENERAL ORIENTATION (BLUE BOOK)
SITE-SPECIFIC ORIENTATION
SUNCOR PRACTICES
CONTROL OF HAZARDOUS ENERGY
FALL PROTECTION
BENZENE
MMMF / NORM
RESPIRATORY PRACTICE
APPLICABLE DRIVERS TRAINING
PPE Requirements & Emergency Preparedness
Identify required PPE and who is responsible to obtain.
Required Training
OPER
CONT
N/A
Comments
STANDARD PPE (HARD HAT, SAFETY GLASSES,
GLOVES, BOOTS, FRC, GAS DETECTOR)
GAS DETECTOR FUNCTION TEST
BREATHING APPARATUS
ADDITIONAL PPE
(IDENTIFY IN COMMENT SECTION)
FALL ARREST EQUIPMENT
EMERGENCY SHOWER /EYE WASH
COPY OF 3 MINUTE AID
RESCUE TEAM REQUIRED / IDENTIFIED
CONTROL ROOM PHONE NUMBER
RESPONSIBLE FOR A EMERGENCY RESPONSE
ALTERNATE EMERGENCY SUNCOR CONTACT
IF APPLICABLE
CONTRACTOR EMERGENCY NUMBER (OFFICE)
Site Supervisor:
Contractor:
I authorize work to proceed according to
I agree that all work will be conducted as per
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conditions and limitations outlined on this
Term Safe Work Agreement.
the conditions and limitations outlined on the
Term Safe Work Agreement.
SIGNED:
SIGNED:
PRINT:
PRINT:
I do understand I have the right and the obligation to refuse unsafe work. I have reviewed and
understand the requirements of the Term Safe Work Agreement. I understand at any time I
may be asked to produce a copy of this document when asked.
PRINT NAME
SIGN
PRINT NAME
SIGN
___________________ / ____________________ ___________________ / ____________________
___________________ / ____________________ ___________________ / ____________________
___________________ / ____________________ ___________________ / ____________________
___________________ / ____________________ ___________________ / ____________________
___________________ / ____________________ ___________________ / ____________________
___________________ / ____________________ ___________________ / ____________________
___________________ / ____________________ ___________________ / ____________________
___________________ / ____________________ ___________________ / ____________________
Note: Contractor must report any unsafe condition, practice or injury immediately, to the Site
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APPENDIX C – PRE-JOB HAZARD ASSESSMENT
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PAGE 27 OF 30
R oles & Responsibilities Discussed and Defined:
All workers familiar with their job specific roles &
responsibilities
I
dentify All Potential Hazards / Controls:
(tick applicable hazards, note details and controls)
Pressure
Rain / Mud / Snow / Ice
Fall Hazards
Equipment Hazards
Ergonomic Hazards
L.E.L.
O2 Level
H2S
Heat
Overhead Hazards
Fire / Explosion
Noise
Gas Release
Cold
NORMS / Benzene
Conflicting Activities
Task Communication
MMMF / Asbestos
Chemical Hazards
Inexperienced workers identified and provided a mentor
Notes:
Additional Hazards Identified and Discussed:
SAFESTART
can cause or contribute to these critical errors...
These four states...
Eyes not on Task
Mind not on Task
Fatigue
Complacency
Rushing
Frustruation
...which increase the risk of injury.
C ontrols Identified to Reduce or Eliminate Risks:
Type of SWP Issued
Hot
Critical Procedures Required
Yes
Cold
Line-of-Fire
Balance/Traction/Grip
Term
N/A
N/A
Additional Checks
Task Specific PPE
Confined Space Entry
Job Supervision
Operator Preparation
Spill Containment
Fire Protection
Procedures Review
Ground Disturbance
Purging
Isolation Requirements
Job Specific Training
Bonding & Grounding
Equipment Operation
Zero Energy / Lock-out
E mergency Preparedness Discussed and in Place:
Emergency Rescue Plan in place
External Emergency Contacts
First Aid & Rescue Personnel Roles identified
Respiratory Protection
Internal Emergency Notification understood
Emergency Transportation
High Angle Rescue Equipment
Wind Indication
Muster Area identified
Spill Response
Comments / Precautions Taken:
Additional Controls Required, Reviewed and in Place:
Personnel Present:
DO C UM E N T T O BE S A VE D F OR 3 M O N T H S !
NAME (Print)
SIGNATURE
COMPANY
Completed cards to be returned to S.E. Supervision
I have participated in the Pre-job meeting, have the required industry certification and clearly
understand all the above information reviewed.
North America Onshore
EH&S Practice
Safe Work Permits
Number:
P103
APPENDIX D – EVALUATION OF SAFE WORK PERMITS
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PAGE 29 OF 30
Procedure:
Supervisor/Operating Authority will:
1.
2.
Reviewed SWP #:
Cold
Hot
Evaluation Form for SWP Booklet
Worksite Information
Equipment / Safety Hazard
Special Requirements
Hot Work Considerations
Hot Work Requirements
Atmospheric Testing
Signatures/Hand back
NI
NI
NI
NI
NI
NI
NI
Y
Y
Y
Y
Y
Y
Y
N
Location of Work
N
Worker Orientation
N
Description of Work
N
Number of Workers
N
Number of Vehicles
N
MOC Considered
N
Time and Date / Extensions
Y
Y
Y
Y
Y
N
N
Appropriately identified to the task
Y
Initialed appropriately to the task
Y
N
Confined Space Attachment
N
Fall Protection Rescue Plan
N
Ground Disturbance Attachment
N
N
Appropriately identified to the task
Y
Critical task procedure number information
Y
N
N
Appropriately identified to the task
Y
Other Considerations
Y
N
N
Appropriately identified to the task
Initialed
Y
Y
Y
Y
Y
Y
N
Initial Test
Y
N
Subsequent Tests
Y
N
At indicated Intervals
N
Appropriate to Task
N
Equipment Issued
N
Site ERP Information
N
Authority(s)
N
Hand Back boxes checked
Comments:
Reviewer Name:
Operating Authority Signature:
Reviewed SWP #:
Circle: Hot / Cold
Equipment / Safety Hazard
Special Requirements
Hot Work Considerations
Hot Work Requirements
Atmospheric Testing
Signatures/Hand back
NI
NI
NI
NI
NI
NI
NI
Y
E VA L U AT I O N 2
ProAct entry #
Worksite Information
Y
Y
Y
Y
Y
Y
N
Location of Work
N
Worker Orientation
N
Description of Work
N
Number of Workers
N
Number of Vehicles
N
MOC Considered
N
Time and Date / Extensions
Y
Y
Y
Y
Y
N
N
Appropriately identified to the task
Initialed appropriately to the task
N
Confined Space Attachment
N
Fall Protection Rescue Plan
N
Ground Disturbance Attachment
Y
Y
N
N
Y
Appropriately identified to the task
Critical task procedure number information
Y
N
N
Appropriately identified to the task
Other Considerations
Y
Y
N
N
Appropriately identified to the task
Initialed
Y
Y
Y
Y
Y
Y
N
Initial Test
Y
N
Subsequent Tests
Y
N
At indicated Intervals
N
Appropriate to Task
N
Equipment Issued
N
Site ERP Information
N
Authority(s)
N
Hand Back boxes checked
Comments:
Reviewer Name:
Operating Authority Signature:
Reviewed SWP #:
Circle: Hot / Cold
Equipment / Safety Hazard
Special Requirements
Hot Work Considerations
Hot Work Requirements
Atmospheric Testing
Signatures/Hand back
NI
NI
NI
NI
NI
NI
NI
Y
Y
Y
Y
Y
Y
E VA L U AT I O N 3
ProAct entry #
Worksite Information
Y
Y
Y
Y
Y
Y
N
Location of Work
N
Worker Orientation
N
Description of Work
N
Number of Workers
N
Number of Vehicles
N
MOC Considered
N
Time and Date / Extensions
Y
Y
Y
Y
N
N
Appropriately identified to the task
Initialed appropriately to the task
N
Confined Space Attachment
N
Fall Protection Rescue Plan
N
Ground Disturbance Attachment
Y
N
N
Appropriately identified to the task
Critical task procedure number information
Y
N
N
Appropriately identified to the task
Other Considerations
N
Appropriately identified to the task
Initialed
Y
Y
Y
Y
Y
Comments:
Reviewer Name:
Y
N
Operating Authority Signature:
N
Initial Test
Y
N
Subsequent Tests
Y
N
At indicated Intervals
N
Appropriate to Task
N
Equipment Issued
N
Site ERP Information
N
Authority(s)
N
Hand Back boxes checked
Evaluation of Safe Work Permits
E VA L U AT I O N 1
ProAct entry #
d. Include improvement opportunities identified in the evaluation process as remedial actions in the ProAct entry for follow up.
e. Attach copies of the evaluated SWP‛s to the evaluation form and forward to Loss Control Advisor.
E N E R G Y
Select three completed SWP (White Copies) and fill out evaluation.
Review all sections of the SWP to determine if they are filled out properly or if improvement is needed.
a. Circle NI (needs improvement) Yes/No and provide comment for Yes findings.
b. If a section of the evaluation form does not apply to the SWP being evaluated indicate it is NA (not applicable).
c. Enter all evaluations into ProAct - Planned Activity Tracking/Audit/TLM/SWP Audit - Ref. #57368 in ProAct test database.