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4 ELEVATED WORK
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PURPOSE: To protect personnel from falls and falling objects while performing work.
SCOPE: Applicable to all facilities operated by EQUATE.
Exemptions:
This procedure does not apply to –
1. Facilities/equipment owned and operated by a third party such as:
a. Public utilities
b. Telecommunications facilities (e.g., telephones, microwave stations)
c. Pipeline, supplier, or raw material leases
d. EQUATE facilities leased to a third party
2. Repair and assembly pits, where the pit access is restricted via covers, locked fences,
locked buildings, floor markings, or warning signs.
3. Emergency response personnel while they are responding to an emergency.
4. Walking on decks in areas intended for access to the cab in self-propelled mobile
equipment (e.g., cranes, excavators).
5. The work practice for management of life-critical guards does not apply to -
- Permanently-installed barricades or guards such as handrails or manhole covers
including:
 Metal guards that are not scaffold material (for example 2.5" X 2.5" X
0.375" angle) welded or bolted in place.
 Wood or fiberglass reinforced (frp) guards that are inherent to the
system (i.e. cooling tower handrail systems and cooling tower decks) and
are bolted or secured in place.
 Manhole or trench covers designed for application (i.e. utility access
covers).
- Metal hole covers attached by either welding or bolting in place.
- Work that creates a floor opening which measures less then 12" in its least dimension
that someone cannot fall through.
- Handrails or midrails on scaffolds that are only preventing the fall hazard created by
the scaffold itself.
- Barricades which have been installed in addition to life-critical guards.
- Personal fall prevention /protection systems.
DEFINITIONS:
Term Definition
Anchorage A secure point of attachment for lifelines, lanyards or deceleration devices.

Aerial lift device Any device, extensible, designed to turn, or both, which is primarily designed and used to
position personnel for elevated work. The device may also be used to handle material if
designed and equipped for that purpose. Examples include:
1) Vehicle-mounted elevating and rotating aerial devices (e. g., boom truck)
2) Self-propelled elevating work platforms (e. g., boom lift), and
3) Boom-supported elevating work platforms (e. g. scissors lift).
Barricade A continuous physical obstruction intended to warn and limit access to an area that may
not be easily recognized as hazardous to persons not involved in the work or when only
authorized persons may enter. Examples of barricades include, but are not limited to, the
following:
1) Barriers
2) Chains (not allowed as fall protection where gratings are removed)
3) Tapes (not allowed as fall protection where gratings are removed)
4) Screens

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Term Definition
5) Guard rails

Critical Elevated The following tasks are considered "Critical Elevated Work" because they pose higher
Work elevated work risks:
a. Critical Scaffold erection and dismantling:
 Cantilevered Scaffold exceeding 3 feet (1 meter)
 Suspended platforms
 Scaffold tents
 Balconies exceeding 3 feet (1 meter)
 Scaffold that uses an existing building or structure for
support/anchorage and the distance between the edge of the
scaffold and the existing building or structure is >1 foot (30
cm)
 Scaffold bridges longer than 25 feet (7.5 meters)
b. Use of crane-suspended work platforms.
c. Work on elevated surfaces that are not protected by fall
prevention/protection systems excluding work from ladders, scaffolds
and aerial lifts
- Cable Trays
- Pipe Racks
- Tank roofs and internal vessel components when personnel load
including equipment exceeds 500 lbs (227kg).
d. Work that creates a life-critical fall hazard (e.g., by removing grating,
removing manhole covers, removing permanent guardrails etc.)
e. Rope Access
Deceleration Any mechanism such as a lanyard or automatic self-retracting lifeline, which serves to
device dissipate a substantial amount of energy during a fall arrest and lowers the person safely
to the ground.
Elevated Work 1. Any work where personnel are working within 6 feet (1.8 meters) of a drop of 6
feet (1.8 meters) or more as measured from the lowest part of the body. For
example:
 Work within 6 feet (1.8 meters) of the edge of a flat roof
 Work done while in or on pipe racks
 Work within 6 feet (1.8 meters) of excavations with an
unprotected edge 6 feet (1.8 meters) or deeper
 Work on top of transportation equipment (tank trucks, rail cars,
etc)
2. Work within 15 feet (4.5 meters) of the edge a low-sloped roof.
3. Work on steep roofs (slope greater than 4 in 12, vertical to horizontal).
4. Work over dangerous equipment and other hazards where the danger of falling
into or onto the hazard exists, regardless of height. For example, work done
over exposed reinforcing bars.
5. Work that creates a fall hazard by:
 Removing grating or permanently installed fall
prevention/protection (e.g., guardrails), or
 Creating an opening through which a person may fall
6. The use of ladders when the users feet are 6 feet (1.8 meters) or higher above

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Term Definition
grade, or use of any ladder within 6 feet (1.8 meters) of a 6 foot (1.8 meters) or
more fall height.
7. The use of aerial lift devices.
Extension A non-self-supporting portable ladder adjustable in length. It consists of two or more
ladder sections traveling in guides or brackets or the equivalent and so arranged as to permit
length adjustment.
Facility Leader Wherever used in this procedure means Unit/Department/Production Leader.
Fall arrest A system used to arrest a person in a fall from a working level. It consists of an
system anchorage, connectors, and a harness and may include a lanyard, deceleration device,
lifeline or a suitable combination of these.
Fall protection Systems designed to stop or control a free fall once a fall has been initiated. Examples
systems include, but are not limited to:
 personal fall arrest systems, and
 safety nets
Fall restraint A system used to prevent a person from falling off an elevated work surface. It consists of
system an anchorage, connectors, and a full body harness and may include a lanyard, lifeline, or
suitable combinations of these.
Fall prevention Systems designed to prevent a fall to a lower level. Examples include, but are not limited
systems to:
 permanently installed systems such as guardrail systems and ladders with cages and
rest platforms,
 personal fall prevention systems such as personal fall restraint systems and
positioning device systems,
 Other systems such as hole covers, warning line systems, mobile ladder stands,
mobile elevating work platforms, and aerial lift devices.
Fixed ladder A ladder, including individual ladder rungs, that is permanently attached to a structure,
(Monkey building, or equipment. It does not include ship’s stairs or manhole steps.
Ladder)
Flat Roof A roof having no slope.
Floor Opening An opening measuring 12 inches or more in its least dimension, in any floor, platform,
pavement, or yard through which persons may fall; such as a hatchway, stair or ladder
opening, pit, or large manhole.
Floor openings occupied by elevators, conveyors, machinery, or containers are excluded
from this definition.
Full-body Straps which may be secured about a person in a manner that will distribute the fall
harness arrest forces over at least the thighs, pelvis, waist, chest and shoulders with means for
attaching it to other components of a personal fall prevention / protection system.
Floor Hole An opening measuring less than 12 inches but more than 1 inch in its least dimension, in
any floor, platform, pavement, or yard, through which materials but not persons may fall;
such as a belt hole, pipe opening, or slot opening.
Grating A grill or network of parallel or crossed bars fixed on a platform floor, designed to
withstand certain load.
Ladder
A device incorporating or using steps or rungs on which a person may step to ascend or
descend.
Ladder Cage A barrier surrounding or nearly surrounding the climbing area of a ladder. It fastens to
the ladder’s side rails, to one side rail, or other structures.

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Term Definition
Lanyard A flexible line of rope, wire rope or strap with a maximum length of 2 meters and with a
minimum size of 13 millimeters nylon or equivalent. This generally has a connector at
each end for connecting the harness to a deceleration device, lifeline or anchorage.
Life-critical A temporary guard that forms the last line of defense to prevent persons from falling to a
guard lower level, when such falls would be generally accepted as life threatening. Examples
include, but are not limited to –
 Guardrail systems
 Covers over open holes in grating
 Warning line systems and barricade tape when no guardrail systems or covers are
installed.
Lifeline A component consisting of a flexible line for connection to an anchorage at one end to
hang vertically (vertical lifeline) or for connection to anchorages at both ends to stretch
horizontally (horizontal lifeline) with a minimum breaking strength of 2272 Kg per person
attached.
The lifeline serves as a means for connecting the other components of a personal fall
prevention/protection system to an anchorage.
Low Slope roof A roof having a slope less than or equal to 4in 12 (vertical to horizontal) or less than or
equal to 10 degrees.
Mobile ladder A mobile fixed-size self-supporting ladder consisting of a wide flat step ladder in the form
stand of stairs. The assembly may include handrails, guardrails and toeboards.
Portable Ladder A ladder that can readily be moved or carried, usually consisting of side rails joined at
intervals by steps or rungs.
Qualified Person performing periodic inspections of Grating, Guardrails, and Stairs. This is a person
Grating who by possession of a recognized degree or certificate, extensive knowledge, training,
Inspector or experience has successfully demonstrated the ability to solve or resolve problems
related to the subject matter.
Rope Access A means of access by descending or ascending a main line (rope) while the worker is
protected by a safety line. Rope access also includes the use of climbing and aid climbing
techniques with fall protection.
Scaffold Any temporary elevated platform (supported or suspended), used for supporting
personnel or materials or both. This term does not include crane or derrick suspended
personnel platforms.
Scaffold Tent An enclosure built with scaffold members supporting it. A tarp is typically used to form
the enclosure. Such tents are typically used for weather protection of equipment by
construction workers. Scaffold members are used to build the tent structure over which
a tarpaulin is pulled. The tent is the combination of the frame structure and tarpaulin.
The fall risk is a combination of building the structure and/or from pulling the tarpaulin (
e.g. wind load) over an existing structure.
Suspension One or more platforms suspended by ropes or other non-rigid means from an overhead
scaffold structure.
Steep roof A roof having a slope greater than 4 in 12 (vertical to horizontal) or greater than 10
degrees.
3- point contact A method of travel to/from an elevated work area using two hands and one foot or one
hand and two feet.
Toeboard A low vertical barrier at floor level erected along exposed edges of a floor opening, wall
opening, platform, runway or ramp to prevent fall of materials.
Warning line A barrier erected on a roof to warn personnel that they are approaching an unprotected
roof side or edge.

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A. General Requirements:
1. Any job involving elevated work must be planned to ensure personnel doing the work are protected from falls
and falling objects.
2. No personnel are allowed to perform elevated work unless they –
a) Have the required training.
b) Are protected from falls at all times. They may be protected via:
 Fall prevention systems, or
 Fall restraint systems, or
 Fall arrest systems
3. Personnel who are potentially exposed to falling objects must be adequately protected (e.g. by wearing helmets
or by using material nets).
4. If any work creates a fall hazard (e.g. removal of grating) the personnel doing the work must protect other
personnel by -
a) Installing temporary guardrails, or
b) Installing hole covers, or
c) Preventing other personnel from accessing the area.
Note: Installation of temporary guard rails and hole covers must be managed according to the requirements
of the Work Practice for Management of Life-Critical Guards (Ref. requirement E).
5. For elevated work on transportation equipment, the facility shall complete an elevated work assessment (TEEW)
using Appendix-E, and completed assessment sheet shall be attached to the SWP.
6. When continuous protection from falls may be infeasible (in exceptional cases)
a) Personnel must minimize the time they are exposed to the fall hazard.
RMD planner shall complete a critical elevated work fall protection plan (Appendix-B) and gain approval of this
plan from the affected facility leader.
7. Equipment used for fall prevention/protection for elevated work must:
a) Meet EQUATE specifications or local governmental requirements, whichever is more stringent.
b) Changes to structures, walkways, grating, etc. require engineering and design review in MOC.
c) Be used according to the manufacturer's instructions.
8. Facility Leader must:
a) Select and implement safeguards to protect personnel from falls, including:
 Elimination of the elevated work
 Installation of fall prevention/protection systems
 Require use of fall prevention/protection systems. Note: Options for safeguards must be selected
from the "Fall Prevention/Protection Options" document. (Appendix-A)
b) Review/approve plans for Critical Elevated Work.
9. All Elevated works require a Safe Work Permit when not performed by an Authorized Operating Procedure User
(AOPU).
10. The following shall not be used as anchorage for fall restraint:
a) Handrails and guardrails (These are not designed as fall arrest anchorage point; may be used as anchorage
after evaluation by RMD planner, in consultation with E&CD; and captured in SJP)
b) Electrical conduits
c) Process piping
d) Cable trays
e) Plastic or FRP pipes
11. For vehicles with mounted elevating and rotating platforms, brakes are set prior to persons occupying the
platforms unless the vehicle is specifically designed to travel with the platform occupied.
12. Erection and Dismantling of Scaffolds shall be performed using RMD procedure ESO-02.
13. Every ladderway floor opening or scaffolding platform shall be guarded by a standard railing with standard
toeboard on all exposed sides (except at entrance to opening), with the passage through the railing either
provided with a double bar swing gate or so offset that a person cannot walk directly into the opening.

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B. Requirements for Critical Elevated Work: Any Critical Elevated Work shall meet the following requirements.
1. Documentation of a “Critical Elevated Work Fall Protection Plan” (Appendix-B) by the RMD Planner. This plan
must be approved by the leader of the affected facility. Any subsequent changes to the plan shall also be
approved using the same Appendix-B.
2. A Safe Work Permit (SWP) approved by the Facility Leader. The SWP approver must review the “Critical Elevated
Work Fall Protection Plan” with the personnel doing Critical Elevated work and must ensure that a copy of this
plan is attached to the SWP.
3. The users of Critical Elevated Work Fall Protection Plan shall sign in the same plan to acknowledge that they
understand the plan. They shall also sign to acknowledge subsequent changes, if any.
4. Personnel planning a Critical Elevated work must ensure surfaces, which are not designed as a walking/working
surface for personnel access, are evaluated to determine if the surface supports the personnel load.
Example: If the materials of construction of the roof seem suspect or the condition of the
roof is questionable.
5. For the use of crane-suspended work platforms, the following additional requirements must be followed –
a) A crane-suspended work platform may only be used if –
 It represents a lower risk than the use of conventional fall prevention/ protection systems, or
 Conventional fall prevention/protection systems are not practical.
b) If a crane-suspended work platform is used, a plan has to be established that includes the following
information:
 Applicable regulatory requirements
 Crane requirements
 Lift plan/checklist
 Full cycle operational test lift
 Responsibilities and accountabilities
 Crane operator qualifications
c) RMD shall develop and maintain a procedure for use of “crane-suspended work platform”.
C. Requirements for the Personnel doing Elevated Work:
1. All personnel doing Elevated Work :
a) Are provided the required training, knowledge and skills.
b) Follow the precautions specified in the SWP/Critical Elevated Work Fall Protection Plan.
c) Shall not alter or modify personal fall prevention/protection systems.
d) Shall not use personal fall prevention/protection systems or components for anything other their intended
purpose.
e) Inspect all the fall prevention and fall protection equipment prior to use. If found defective, label and
remove the same from service and communicate it to the RMD Maintenance Activity Coordinator. Do not
reuse the fall protection equipment if subjected to impact loading.
f) Use the fall prevention and fall protection equipment according to the manufacturer's instructions.
g) Stop the job and communicate to the facility representative any job scope changes or conditions that may
result in new fall hazards (e. g., removal of grating, guardrails or hole covers).
h) Do not throw tools and materials up to or down from an elevated work area. Use appropriate hoisting and
lowering practices.
2. Personnel using a fall restraint or fall arrest system must –
a) Be trained on the proper use of the system.
b) Use the equipment properly (as described in the training).
c) Use a safety harness for fall arrest system.
d) Limit the free fall distance to a maximum of 6 feet.
e) Snap hooks shall not be engaged to a D-ring to which another snap hook or other connector is already
attached unless specifically designed for the purpose and authorized by the manufacturer.
f) Ensure that your weight, plus the weight of the tools you are carrying does not exceed the weight limits of
your system. (Note: Most systems are designed for a weight of 140kg).

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3. When using an aerial lift device:

a) Keep the base on level and stable surfaces.
b) Use personal fall protection connected to the anchorage provided by the manufacturer at all times while in
the confines of the aerial lift device.
Exception: Personal fall protection is not required while working over water while in an aerial lift device.
Personal flotation device (life vest) is required for work over water.
4. If you are using a safety net system, you must remove any materials, scrap or tools that may have fallen into the
safety net as soon as possible.
5. If you fall, or are saved from a fall by the fall restraint or fall arrest system, you must:
a) Report the fall to the immediate supervisor and facility leader.
b) Label and remove the fall restraint or fall arrest system you were using from service.
c) Inform T&I to inspect the system.
6. Requirements for using crane-suspended work platforms:
a) Follow RMD procedure for use of “Crane Suspended work platform”. Complete the checklist contained in
this procedure prior to starting the job as per the requirements. Attach the completed checklist to the
SWP.
b) Obtain a Safe work Permit before the lift.
c) During the lift, use a fall restraint system anchored to the basket or a personal fall arrest system anchored
to the boom.
d) Do not use the platform for anchorage for persons working outside the basket.
7. Requirements for doing critical elevated work:
a) Read, sign and date the Critical Elevated Work Fall Protection Plan before starting the job.
b) Keep a copy of the Critical Elevated Work Fall Protection Plan at the job site.
c) Follow all instructions included in the Critical Elevated Work Fall Protection Plan.
D. Requirements for Ladders:
1. Ladders must:
a) Meet EQUATE specifications or local regulations, whichever is more stringent.
b) Be used in accordance with the manufacturer's instructions.
2. If you use a ladder (e.g. fixed, portable, scaffolding), you must:
a) Slowly and carefully, climb and descend all ladders.
b) Maintain 3-points of contact at all times while climbing or descending.
c) Have both hands free for climbing (i.e., do not carry tools in your hands while climbing).
d) Minimize work from a ladder.
e) Keep your upper body between the side rails of the ladder (unless fall protection is used).
3. Fixed Ladders:
a) For Existing Fixed Ladder Openings With No Chain Or Gate: A self-closing double bar swing gate shall be
installed as soon as possible. (*)
Exception: On tall columns/long ladder runs where the platform is a landing (rest area) as opposed to a
working platform no chain or gate is required. A chain or gate is required on all working platforms. Where
working platform is too small to install a gate, a chain maybe installed as long as it is maintained and used
properly.
b) For Existing Fixed Ladder Openings with Chain: The chain shall be covered under T&I program by RMD and
used appropriately (connected while the platform is used). If the chain is in poor condition (chains typically
corrode and there is no self-closing mechanism), it shall be replaced with a self-closing double-bar swing
gate.
c) For Existing Fixed Ladder Openings with Self-Closing Single-Bar or Double Bar Swing Gates: The gates shall
be covered under T&I program by RMD and used properly. Single-Bar gates that are not automatically
closing shall be replaced with self-closing double bar swing gates.
d) For New Fixed Ladder Opening: A double bar swing gate shall be installed.

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e) For Existing or New Fixed Ladder Openings where the ladder passes through the working platform versus
being attached to the side of the platform: A double bar swing gate should be installed.
* Ref: Dow Engineering Practice G2G-5515-20
f) Swing gates and chains provided for fall protection at ladder openings should always be in the closed
position, except when a person is passing through the opening.
g) Ladder cages shall be provided on fixed ladders of more than 6m (20 feet).
4. Portable ladders:
a) Inspect the portable ladder for defects or damage prior to use.
b) Place the ladder on secure footing on a firm, level support surface.
c) Use shoes, spurs, spikes, or similar devices as needed to keep the ladder from slipping or sinking into the
ground.
d) The use of portable ladders must be restricted to a specific task. (Like valve operation or point inspection).
e) When using a portable ladder close to a guardrail, if you are working within 6 feet (1.8 meters) of a drop of
6 feet (1.8 meters) or more -
 Increase the height of the guardrails, or
 Use fall prevention/protection.
5. If you are using an straight ladder or extension ladder:
a) Place the base of the ladder so that the horizontal distance from the top support to the base is
approximately one-quarter of the working length of the ladder
b) Secure the ladder at the top before using it for elevated work. Have another person hold the ladder in
place at the bottom while you are securing the top.
c) If the ladder is used to gain access to another work surface, the ladder must extend at least three rungs
above the surface, or a grab rail must be provided.
6. A Jacob’s ladder (rope ladder) shall not be used without a third party load test certificate before use. Fall
prevention and/or fall protection systems must be used when using a rope ladder, if there is a potential for a
person to fall 6 feet (1.8 meters) or more.
7. The following periodic inspections have to be conducted by T&I representative and documented. The person
responsible for testing and inspection provides a label or tag mentioning the date of inspection and the next due
date for inspection.
 Inspection of fixed ladders / fixed ladder cages in accordance with the manufacturer’s instructions or
at least every 36 months using Appendix-C. If the inspection reveals serious deficiency, barricade the
Ladder and alert others with a tag “Do not use” until repaired.
 Inspect all portable ladders in accordance with the manufacturer’s instructions or at least annually
using Appendix-D. If the inspection reveals serious deficiency, remove the Ladder from service and
alert others with a tag “Do not use”.
E. Work Practice for Management of Life-Critical Guards:
1. Prevent access to temporary openings (openings created by work) where a life threatening fall hazard exists by
installing a life-critical guard (temporary guardrails or floor-opening covers) or someone in continuous
attendance. Life-critical guards must remain in place until the fall hazard has been removed.
Note - Continuous attendance after the guard is removed (or once the hazard is created and until the guard is in
place) is acceptable for a maximum of 2 hours when a watch person(s) can prevent entry into the fall hazard
area from all possible accessible sides.
2. Life-critical guards must be installed, modified or removed by personnel who have been properly trained and
authorized through a Safe Work Permit.
3. Apply requirements of Critical Elevated Work for the management of life-critical guards.
4. All grating removal work (when potential for fall is 1.8 meters) shall only be allowed on an approved Safe Work
Permit. Job representative shall attach a copy of an area plot plan to the permit, clearly indicating the exact
location where the grating has to be removed or floor opening needs to be created.
5. On completion of the work, job representative and facility representative shall inspect the work area to ensure
the grating is properly replaced and secured and that the area is completely safe. The Facility Representative and

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the Job Representative complete Grating inspection checklist if grating is removed, repaired, added, or modified
in any way.
6. All floor openings shall be barricaded, when feasible, with bolted down steel pipe structure or scaffolding
structure, at least 5 feet in height with 2 guard rails at about 18" distance on all sides to prevent inadvertent
entry, provide "Do not enter" signs at all accessible sides of the floor openings and hazard signaling flashing
lights. (See note at E.1)
7. If floor openings are temporarily covered then the cover shall be constructed of material having sufficient
strength to withstand a load of at least 300 Kg and be properly secured.
8. Personnel may enter areas guarded by life-critical guards if:
a) they have completed the required training for Personnel Doing Elevated Work, or are accompanied by
someone who has completed the training for Personnel Doing Elevated Work if they are not doing
elevated work themselves, AND
b) are using the proper fall protection / prevention equipment.
9. After erecting, modifying or removing a life-critical guard, inspect the worksite with Safe Work Permit Issuer or
his representative.
F. Work Practice for Grating Inspection Management:
1. Site shall have a procedure for Inspection of Grating, Guardrails, and Stairs.
2. Site Grating Focal Point & Qualified Grating Inspectors shall be identified and trained by RMD Leader.
3. Divide the facility or area into sections that can be easily segmented and identified (i.e. structure levels, small
process areas, etc.). The grating inspection of a section should be completed during one grating inspection task
using one checklist per section (i.e. reactor area, catalyst area).
4. Specific area or section shall be assigned to a qualified grating inspector. It is preferred that no other duties are
performed while executing grating inspections. The potential for distractions should be minimized.
5. For each area within the facility, a CTT/MTL task shall be listed.
6. Grating clips/weld joints shall be painted during inspections, as per the Grating Inspection Procedure. The paint
color shall be consistent across the site.
7. Color codes to be used for each subsequent 3 year inspection shall be as per RMD procedure SAF-18. If a clip
fails inspection, it shall not be marked with the new inspection color. Each clip/weld joint shall be painted with a
spot of paint at the time of inspection.
8. Where grating is fastened with welds to the support instead of clips, each weld shall be painted using the same
color codes as for clips.
9. Unique or non-standard grating installations, if found, shall be evaluated, and if deemed to be acceptable, the
Site grating focal point shall document these pieces of grating in an equipment history file with photos and other
supporting data so that these pieces of grating do not have to be re-evaluated after future inspections.
10. Grating inspection records shall be retained for 10 years.
11. Grating inspections shall be carried out at 3-year frequency.
12. A tracking system shall be in place to track periodic Grating inspections.
13. Corrective actions shall be documented in the AITS (as CAPA) to close the identified gaps.
G. Workpractice for Rope Access:
1. A documented rope access work plan prepared by the rope access supervisor (Level III technician) must be in
place before the rope access work starts. Plan must include the following elements.
a) List the rope access system and equipment to be used.
b) List the members of the work team by name and identify their duties.
c) List the hazards associated and actions to be taken to mitigate the hazards.
d) List appropriate PPE.
e) List precautions for securing the anchor location.
f) Describe the rescue plan.
2. Each rope access technician must have a main and a backup system.
a) Both systems must work independently.
b) The two systems must be connected to the technician at all times, including during rope transfer.
3. Notify Incident Commander before the rope access work starts and ends.

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4. Rope Access is prohibited for open flame work, hydroblasting, high pressure water cutting, abrasive blasting and
Line and Equipment Opening (L&EO) which trigger the L&EO additional hazard analysis.
5. Personnel who plan jobs for rope access must:
a) Inspect the worksite together with the rope access supervisor (Level III technician)
b) When required (see requirement below), initiate a rope access hazard assessment and include the results
in the rope access hazard assessment (Appendix-K).
6. Rope Access Hazard Assessment (Appendix-K): A rope access hazard assessment shall be documented for tasks
that pose higher risks (see examples listed below). The rope access hazard assessment must be reviewed and
approved by the Facility Leader and the RMD Leader or the relevant unit MFT Leader.
 Any mechanical task with the potential to result in a double rope cut (e.g. grinding, power
sawing, welding)
 Any job where the required PPE could result in higher stress on worker, or limited mobility.
 Demolition with the potential to affect anchorage points or result in a double rope cut.
7. Personnel doing rope access must:
a) Be certified as a rope access technician (can be Level I, II or III Technician) from IRATA or equivalent
agency.
b) Have a minimum of three certified rope access technicians present, for each task, when rope access
equipment and techniques are used. One of the three must be a rope access supervisor (Level III
technician).
c) Follow the rope access work plan.
H. Inspection requirements:
1. Fall Protection/preventions systems shall be inspected (Appendix-G) as per manufacturer’s instructions or at
least annually.
2. Portable ladders shall be inspected (Appendix-D) as per manufacturer’s instructions or at least annually.
3. The following shall be inspected as per manufacturer’s instructions or at least every 3 years:
a) Gratings (refer to RMD procedure – SAF-18).
b) Fixed ladders, ladder cages (T&I rep must do complete this as per Appendix-C).
c) Mobile platform and mobile loading racks (T&I rep must do complete this as per Appendix-H).
4. Scaffold weekly inspection (Link) shall be carried out as per checklist in the RMD procedure (ESO-02) for
“Erection and Dismantling of scaffolds”.
I. Documentation Requirements:
1. Critical Elevated Work Fall Protection Plan (Appendix-B)
2. RMD scaffolding procedure ESO-02.
J. Recordkeeping Requirements:
For the issued SWPs, follow the Safe Work Permit (EHS-5.3) record retention requirements.
K. Audit and Self-assessment requirements:
Each Facility shall conduct annual self-Assessment using Appendix-F. The person(s) conducting this self-assessment
must have completed training on this procedure.
L. Training Requirements:
1. Department Leaders at plant site, Production Leaders, EH&S Delivery Leaders, Personal Safety Expert, Persons
Issuing SWP, Job representatives, Facility representatives, Planners (RMD), PACs, WACs (RMD) and contractors’
personnel who perform elevated work shall receive training on this procedure.
2. Retraining is required every three years and when there is a substantial revision to this procedure.
M. Roles & Responsibilities:
Role Responsibility
Facility leader 1) Ensure compliance with the requirements of this procedure in the facility.
2) Ensure annual Self-assessment is conducted on this Procedure.
3) Review/approve plans for critical elevated work.
4) Review and approve rope access hazard assessment.
RMD Site Leader 1) Ensure that Work Practice for Grating Inspection Management requirements (F) is
implemented.
2) Establish training requirements for Qualified Grating Inspector(s). Training must be

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Role Responsibility
conducted initially and at least every 3 years.
3) Review and approve rope access hazard assessment.
RMD 1) Inspection of fixed ladders, ladder cages as per manufacturer or at least every 36
T&I Representative months.
2) Inspection of portable ladders as per manufacturer or at least annually.
3) Inspection of Mobile platform and mobile loading racks as per manufacturer or at
least every 3 Years.
Facility 1) Comply with the role specific requirements of this procedure.
Representative 2) Complete the grating inspections as per manufacturer or at least every 3 Years.
Job Representative 1) Comply with the role specific requirements of this procedure.
2) Complete the grating inspections if grating is removed, repaired, added, or modified
in any way after work is done.
Personnel doing As per requirements listed “General Requirements”.
elevated work
Civil Engineer Provide engineering support and guidance on grating questions and issues.
(E&CD)
Qualified Grating 1) Perform periodic inspections of grating associated with the compliance task.
Inspector Inspect Grating, Guardrails, and Stairs.
2) Have the required training.
3) Review the area to be inspected for any obvious hazards that may affect them
during the assessment before beginning the grating inspection assessment.
Example: Ongoing work, overhead lifting, high traffic in a congested area
4) Use the Grating Inspection Procedure for grating inspection.
Site Grating Focal 1) Segment the facility prior to inspections beginning.
Point 2) Support qualified inspectors in the grating inspection assessment.
3) Address any deficiencies that may need barricading or life critical guard.
4) Collect completed grating inspection checklist and create log of deficiencies that
will require further follow-up to address.
5) Once facility inspection is complete, determine path forward to close gaps.
6) Once facility inspection is complete and path forward has been determined, enter
CAPA in to AITS to document the required gap closure plan.

N. Implementation Guide:

O. Practice & Guidance: See FAQ.

P. Document History:
Approved by: EH&S Department Leader Date: 28-02-17
The following information documents at least the last three changes to this document, with all changes listed for
the last 3 months (most current is first).
Review Date Activity by Activity
16 Jan 2017 Bhanu Modified requirements for TLCG.
MOC # EHS-16Jan2017-32609

31-Aug-15 Bhanu Reviewed. No changes made.

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Revise Date Activity by Activity

16 Jan 2017 Bhanu Modified requirements for TLCG.
MOC # EHS-16Jan2017-32609
03-Dec-13 Bhanu Added requirements related to ‘Rope access’ activities. Aligned with Dow
global requirements.
MOC # EHS-03Dec2013-21027
19-Feb-11 Bhanu Revised requirements to align with Dow global elevated work standard.
MOC# EHS-19Feb2011-7541
17 July-07 Sabir Modified Training requirements to identify the roles that should be trained
on this procedure. MOC # EHS2007070002
20 Oct 2005 Sabir As per L3E document control requirement.
1. Document history block added
2. Header/footer modified.

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