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KOC.SA.

026 - Excavation Safety Procedure


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Excavation Safety Procedure


Document Number: KOC.SA.026

Document Author: TL Safety Document Coordinator: TL Standards

Approved by: KOC HSEMS Procedures Sub-Committee

Authorized by: KOC HSSE Implementation Committee

Original Issue Date: 26th August 2008 Document Control Tier: Tier 3
Revision / Review
18th February 2014 Next Review Date: 17th February 2017
Date:

1.0 Purpose / Scope


The purpose of this procedure is to establish the precautions and conditions considered
necessary for safety of the personnel involved in excavation work as well as integrity of
above / underground services &/or facilities where such excavation work shall be carried
out. The procedure is also aimed to define the roles & responsibilities of personnel
associated with requesting, approving and carrying out excavation in areas under KOC
jurisdiction.

The procedure is applicable to all activities & facilities where excavation is carried out for
maintenance, construction or inspection need. It is to note that requirement of work permit
for excavation work shall be dealt in compliance with Permit to Work Procedure.

2.0 Definitions
Backfilling: It is an activity to fill-in (with soil) a trench that is no longer needed and
returning the area around its original condition.
Benching: It is also one of the measures to prevent cave ins by cutting trench sidewalls
to form one or more steps.
Cave - ins: It is collapse of the trench side walls due to weight of the adjacent soil. A cave
in can drop several cubic meters of soils on trench worker.
Excavation: Excavation is a man made cut, cavity, trench or depression in an earth
surface or sub-surface, formed by earth removal.
Excavation Notification: Excavation Notification is a document to notify concerned
authorities, who have responsibility and jurisdiction for safety & integrity of aboveground and
/ or underground services existing at the proposed site of excavation.
Good Soil: Cohesive soil with an unconfined compressive strength of 1.5 tons per square
foot (144 kPa) or greater.
Manual Excavation: The excavation without using any powered equipment or excavating
machinery such as backhoe, loader, Jack Hammer etc.
Mechanical Excavation: The excavation work using powered equipment or excavating
machinery such backhoe, loader, Jack Hammer etc.
Medium Soil: Cohesive soil with an unconfined compressive strength greater than 0.5
tons per square foot (48 kPa) but less than 1.5 tons per square foot (144 kPa).

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Metal Detector: It is a device to screen the excavation area to mitigate the risk of
damaging unknown pipelines, cables and utilities.
Poor Soil: Cohesive soil with an unconfined compressive strength of 0.5 tons per square
foot (48 kPa) or less.
Shoring: Shoring involves the use of engineering structures (such as cross braces,
vertical & / or horizontal rail, polling boards etc.) to support a trench side walls.
Sloping: Sloping is angling the sides of an excavation to prevent cave ins.

3.0 General Requirements


KOC HSEMS Element HSE 5-2

4.0 Key Responsibilities

4.1 Permit Issuer


Ensure safety & integrity of the worksite prior to issuance of appropriate permits
(Cold Work Permit for Manual Excavation and Hot Work Permit for Mechanical
Excavation) and related Job Safety analyses (JSAs) for safe work execution.
Ensure that the Excavation Notification had been filled up and signed by all
concerned Teams representatives by verifying the drawings.
Ensures that all mobile equipment used at worksites possess valid clearance
certificates as per HSEMS Procedure KOC.SA.013 for Mobile Equipment.
Check the site for restoring to original conditions before closing the work permit
and excavation notification.
Inform Fire Team if the excavated area may cause obstructions to the main access
to the facility and major operational areas such as Storage Tanks without alternate
routes.

4.2 Permit Applicant / Initiator of Excavation Notification


Initiate Excavation Notification informing concerned authorities, who have
responsibility and jurisdiction for safety & integrity of aboveground and / or
underground services existing at the proposed site of excavation.
Enclose drawings & sketches (with the Excavation Notification) marking the
proposed site of excavation.
Identify the above / underground services (such as pipelines, cables, sewage,
flume, tunnel etc.) before excavating the area without damage to those services.
Obtain necessary Explosive Ordinance Disposal (EOD) clearance certificates as
per HSEMS Procedure KOC.SA.025 for Handling of Explosive Materials,
Substance and EOD.
Ensure risk assessment and mitigation of potential hazards associated with
proposed excavation work as part of Job Safety Analysis (JSA) prior to applying
the appropriate work permit (Cold Work Permit for Manual Excavation and Hot

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Work Permit for Mechanical Excavation) for carrying out excavation work. Please
refer to sub-sections 5.1 & 5.2 of this procedure for additional information.
Ensures that all necessary materials used for cave-in protection & isolation (like
hard barricades, warning signs & flash lights) of the excavated trench/area are
available at worksite before commencement of the excavation.
Ensure that earthworks are not commenced until the Permit Issuer approves the
methods of excavation, the means of support to sides of excavation, the safety
and support of neighboring private and public property, the system of dewatering,
the demolition of existing surface and underground structures and obstacles,
moving of any existing services, pipes, culverts and the like on the side or affecting
the works.
Ensure that the excavation is compacted and backfilled after the work is over.

4.3 Worksite Supervisor


Must not excavate without a valid excavation notification & authorized work permit.
Ensure safety & suitability of the equipment & materials to be used for excavation.
Conduct Tool Box Talk briefing the workers on potential hazards and precautionary
measures to be taken during excavation activities.
Verify the existence of above / underground services before excavating the area.
Barricade the site of excavation along with the reflective warning notices, signs
and flashing lights to alert the people approaching worksite.
Ensure that job information are posted on each excavated area for traceability
purpose: Contract Number, Contract Title, Superintendent of the Contract,
Controlling Team, number of work permit and excavation notification, contact
numbers in case of emergency, etc.
Check the excavation safeguards (such as shoring, sloping & supporting system)
daily before starting the job & after every rain storm or other hazardous occurrence.
Fill the excavation checklist (Refer to Appendix 1) ensuring safety & integrity of the
worksite.
Take all necessary steps to protect any existing services, drains, water and gas
mains, power and telephone cables and the like endangered by excavations and/or
slips and falls, and shall affect all necessary repairs. If any such utilities are
encountered, the pipes, cables, etc., shall be protected as directed by the Permit
Applicant or Asset Owner for Above / Underground Services.
Separate the excavated soil into those suitable for fill and those unsuitable for
backfill.
Remove the materials unsuitable for backfill shall, as soon as practicable,
preferably immediately after excavation and other from the site and legally
disposed off as per HSEMS Procedure KOC.EV.008 for Waste Management.

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4.4 Asset Owners for Above / Underground Services


The respective asset owner for aboveground / underground services will indicate
(in the Excavation Notification); the required precautionary measures to be taken
preventing any damage to those services at the proposed site of excavation.
Mark in the drawings / sketches attached to the Excavation Notification the
locations and depths of the services.

4.5 Asset / Directorate HSE Teams


Conduct periodical inspection of excavation site to assure the procedural
compliance.
Advise the Permit Applicant, Permit Issuer and Worksite Supervisor for corrective
measures in case discrepancy is noticed at the site of excavation.

4.6 Fire Team


Assess the risk and mitigation needed in case of bund wall cutting or excavation
works that might affect the integrity of the bunded area and its ability to act as a
secondary containment during storage tank leaks.
Endorse the Excavation Notification ensuring required control measures against
the bund wall cutting or excavation work affecting the integrity of the bunded area
for the storage tank.

5.0 Safety in Excavation


5.1 Hazards of Excavation
The following hazards may be encountered while excavating or working inside a trench:
Cave ins or collapse of soil / earthwork
Buried alive under earthwork / collapsed soil
Underground obstruction or damage to buried pipelines & services
Accidental fall of personnel or equipment inside a trench
Struck / hit by excavating machinery
Dropped / falling objects
Flammable & / or toxic gas release
Exposed to airborne contaminants
Fire & explosion
Electrical shock due to contact with energized electrical / telecom cable.
Drowning due to water seepage into trench
Soil vibration due to machinery / heavy vehicles operations in the vicinity.
Possible presence of explosive devices
Lack of Oxygen or asphyxiation

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Damage to shallow underground services due to weight of heavy equipment such


as mechanical excavator.
Encountering wet soil (mixed with water) or reaching water table.
Encountering contaminated soil

The above mentioned list is not exhaustive and it is recommended to carry out a site
specific risk evaluation to identify additional hazards as well as to incorporate mitigation
accordingly.

5.2 Control of Excavation Hazard


Excavation accident can only be prevented by identifying & controlling their inherent
hazards by:
Evaluating the hazards at site before and after excavation
Site Specific Risk Assessment & Job Safety Analysis
Approval and authorization through Excavation Notification & Work Permit

Based on the site specific risk evaluation; an excavation plan shall be developed and
attached to the excavation notification form. The following aspects shall be addressed in
the plan:
Size and purpose of excavation
Proposed excavation method (i.e. manual or mechanical)
Nature of soil being excavated.
Nature of soil surrounding the excavation
Stability of adjacent structure
Static and dynamic loads near the excavation
Position of any underground services (such as pipelines, cables, utilities)
Sources of soil vibration
Traffic condition on the adjacent road
Nearest road for quick access / egress from the site
Weather & soil moisture condition
Existence of Plant and equipment beside the excavation.
Slope of the ground around excavation site.
Overhead electrical cables over or around the site.
Presence of manifold / flowlines
Presence of Process pits, sewage pits, burn pits, flares, etc.
Public safety
The length of time the excavation is to remain open
Control measures

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5.3 Excavation Notification & Work Permit


Excavation Notification & appropriate work permit(s) are essentially required for all
excavation work regardless of its depth. The following considerations shall be taken into
account in this regard:
a) Prior to raising an Excavation Notification, the proposed site of excavation must be
thoroughly inspected to assess any underground / aboveground obstructions such
as pipelines, cables, manholes, fire hydrants etc.
b) The excavation notification must accompany a clear drawing of the proposed
excavation site to help specifying precautions prior to its endorsement.
c) The excavation notification shall be endorsed by concerned authorities, who have
responsibility and jurisdiction for safety & integrity of above / underground services
existing at the proposed site of excavation.
d) In case of cutting the bund wall or excavation works that might affect the integrity of
the bunded area and its ability to act as a secondary containment during storage tank
leaks, the Excavation Notification shall be endorsed by Fire Team.
e) In addition to excavation notification, a hot work permit shall be required for any
excavation work involving mechanical excavator; whereas cold work permit is
needed for manual excavation.
f) The excavation notification as well as work permit must be cross referenced with the
other live permits & excavation activities in the vicinity of proposed excavation site.
g) Job information shall be posted on each excavated area for traceability purpose:
Contract Number, Contract Title, Superintendent of the Contract, Controlling
Team, number of work permit and excavation notification, contact numbers in case
of emergency, etc.
h) For safe excavation jobs, the flowchart in Appendix 2 shall be followed.

5.4 Control Measures for Excavation


The following precautionary measures must be taken to ensure safety of the personnel as
well as integrity of the worksite:
a) No excavation work in KOC area shall be taken without ensuring Explosive
Ordinance Disposal (EOD) clearance for that location.
b) No mechanical excavation shall take place closer than 5 meters to any hydrocarbon
carrying pipeline. Such restriction will apply even for levelling (with the use of
mechanical excavator) at a worksite near hydrocarbon carrying pipelines.
c) Similarly no mechanical excavation shall take place closer than 3 meter to a non-
hydrocarbon carrying pipeline, cables and services. However for any mechanical
excavation closer than 3 meter to pipelines, cables or services, it is recommended to
apply Management of Change, thorough risk assessment and control measures.
d) In order to reduce the risk of striking the pipe or underground services, the excavation
will start at the side of the pipeline or midway between parallel lines. Manual slit trench
shall be done along the length of identified underground services at appropriate
intervals in the area marked for excavation in order to expose and positively locate
such known or suspected underground services before commencing the use of

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mechanical excavator at the work site. The appropriate interval for pilot slit trench
shall be indicated in the Job Safety Analysis (JSA) sheet.
e) Manual Slit trench in X-cut, shall be performed to ensure that underground services
are identified, if any, prior to excavations for temporary & permanent Evaporation Pit
/ Pond or any other deep foundation activities.
f) Ground conditions shall also be assessed to confirm additional protection for shallow
buried services prior to deploying any mechanical excavator at site.
g) Excavations adjacent to buildings or other obstructions may require temporary
support, and accordingly the relevant safety instruction must be stated in the
Excavation Notification before taking up excavation activity.
h) Use of trench-box, while working inside trenches at close vicinity of roads / Heavy
vehicle movement.
i) For any excavation deeper than 1m, suitable ladder must be positioned projecting a
minimum of 1 metre above the edge of the excavations. Ladders shall be provided
every 7.5 meters (25 feet) of lateral travel in the trench. Ladders shall be securely
supported at the bottom as well as at the top. Where provision of ladders is not
feasible, access & egress shall be provided by means of a ramp, steps, stairways or
any suitable safe means of access.
j) Any walkway across trench shall have scaffold type platform with handrails to protect
personnel from falling into it.
k) All trenches shall have barrier (such as fixed guardrails) and reflective warning
notices clearly displayed. Flashing lights are mandatory during poor visibility.
l) Excavated material shall be placed at a distance not less than 1m from the edge
of the excavation for depth up to 1.2 meter. Accordingly placement of excavated
material shall be increased proportion to the depth of excavation.
m) Adequate measures shall be taken to remove the piled up soil at the edge of
excavation on a regular basis.
n) Heavy equipment, material or excavating machinery shall be kept clear from the
excavation area by at least 3 metres away.
o) The access to plant, equipment and emergency services must not be obstructed by
the trenches.
p) The trenches shall not be left uncovered in the plant area and must be backfilled
immediately on completion of work.
q) For the non-plant area, the trenches may be left covered and barricaded up to the
expiry of the work permit. In such cases, the same must be specified on the work
permit and the Permit Issuer must be informed for his approval. Necessary control
measures shall be indicated in the Job safety Analysis and implemented carefully by
the Permit Applicant and the Worksite Supervisor.
r) No mechanical excavation is allowed inside the existing KOC facilities (Gathering
Center, Booster Station, water injection and handling facilities, etc.)
s) Personnel carrying out excavation work must use Personal Protective Equipment
(PPE) in line with the requirements of HSEMS Procedure KOC.SA.010 for Personal
Protective Equipment and as indicated in the Job Safety Analysis (JSA) sheet.

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t) Employees exposed to public vehicular traffic shall be provided with, and shall wear;
warning vests or other suitable garments marked with or made of reflectorized or
high-visibility material. As per KOC.SA.036 for Safe Work Practice While Working
on Road.
u) Equipment which are run on internal combustion engines shall not be kept inside the
excavated area to prevent accumulation of toxic smokes such as Carbon Monoxide
(CO) and Carbon Dioxide (CO2).

5.5 Inspection of Trenches


To identify and control hazards all parts of a trench and its safeguards must be inspected by
the Worksite Supervisor everyday in consideration to following issues:
a) All materials to be used in shoring & support must be inspected for its suitability
b) The timbering and shoring must be checked for any strain or slackness before
commencement of daily work. Moreover timbering and shoring must also be checked
carefully after heavy rains and or exposure to high temperature.
c) All excavations must be carefully inspected following after any event that may have
affected their strength or stability such as heavy rains for collapse of trenches or fall
of equipment or materials inside.
d) If an unsafe condition is found or suspected, work in trenches must stop until the
necessary precautions have been taken to control the hazards.
e) Necessary records of inspection of trenches should be maintained.

5.6 Excavation Process


5.6.1 Excavation in Good Soil
a) For excavations in good soil, shoring is not usually required, provided the
excavations depth does not exceed more than one metre
b) If the surface area permits, greater depth can be made by sloping the side
down to an angle of 45.
c)If surface area is limited and needed excavation depth is more than one metre,
then polling boards must be placed approximately two metres apart with
horizontal brace (support), whereas horizontal brace should not be more than
one metre apart.
d) Where a long trench is being made, the mechanical digging must be limited
to approximately two metres ahead of shoring to give a protected position.

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5.6.2 Excavation in Medium Soil


a) If the depth of the excavation exceeds one metre, shoring must be used.
Sheeting shall project at least 450mm (18") above ground level to prevent
falling objects. The polling boards should be placed not more than 750mm
(30") apart facing the wall, whereas horizontal brace should not be more than
one metre apart.
b) Extra polling boards should be inserted across if the condition of the ground
deteriorates.
5.6.3 Excavation in Loose Sand or Poor Soil Condition
If excavations are to be made in loose sand or poor soil condition, then close sheeting
or continued series of polling boards shall be used.
The polling board & walling shall have a minimum cross-section as mentioned
hereunder:
Polling board = 200mm x 50mm, (8" x 2")
Walling = 150mm x 50mm (6" x 2")

5.6.4 Using Excavation Machinery


The use of excavating machinery (such as backhoe, jack hammer, loader etc.) near
above / underground services will require a Hot Work Permit in addition to Excavation
Notification. The following precautions are to be taken while using mechanical means
of excavation:
a) Extreme care shall be taken to prevent any damage to above / underground
services or power lines while using mechanical excavators.
b) A mechanical excavator shall not be used until all underground obstructions
have been uncovered through manual excavation. Once underground
services are exposed the area should be further excavated manually as per
clause 5.4 b & c on either side of the exposed services before using
mechanical excavator.
c) Mechanical excavation shall not be carried out while personnel are inside the
trench/excavation.

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d) The machinery operator shall take extra care and follow banksman instruction
while reversing or turning the excavator to prevent any accidental strike to the
workers or equipment at location.
e) The bucket must always be lowered to the ground if the loader or backhoe is
not in operation.
f) The machinery operator shall take necessary care to prevent exhaust gases
entering the nearby trench or pit, in case personnel are working inside it.
g) Workers should not be permitted to work under raised loads and must be
protected from loads or objects falling from equipment involved during
excavation.

5.6.5 Prevention of Accidental Fall inside a Trench


Adequate fencing, barriers and reflective warning notices are to be provided around
any excavated area to alert and prevent accidental fall into it. Posting flaggers and /
or watchman will be required if the trench is in a heavy traffic area. It is also
recommended to illuminate the excavated area in the night and provide flashing
hazard light. Any person entering the barricaded area must follow safety procedures
to eliminate fall from height hazard in line with requirements of HSEMS Procedure
KOC.SA.031 for Working at Height. Where equipment, workers or public are
required or permitted to cross over a trench; then it is essential to provide a close
planked bridge or walkway with standard guard rail.

5.6.6 Trench as Confined Space


An excavation that exceed 1.2 meter shall be treated as Confined Space and shall
be checked for toxic gas, flammable gas as well as lack of oxygen. In such situation
the requirement as applicable to Confined Space Entry Permit will be adhered.

5.6.7 Backfilling & Reinstatement


If a trench is no longer needed then it has to be backfilled returning the area around
it to its original condition. The following precautionary measures to be considered
while backfilling a trench:
a) Backfilling and removal of trench support shall be taken from the bottom
of the trench layer by layer.

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b) The trench will be backfilled up to the level that allows removal of lower
brace. After removing lower brace, the trench will be backfilled further to
remove next level of braces. This process will be repeated until the trench
is completely backfilled.
c) In case of soil being unstable; the removal of brace / trench support shall
be made with ropes from outside the trench without worker entry it.
d) Removal of trench support shall be done slowly preventing collapse of side
wall.
e) Any surplus excavated materials shall be removed from the site making it
tidy and compact.
f) No contaminated soil shall be used for backfilling, whereas contaminated
soil shall be disposed complying with HSEMS Procedure KOC.EV.008 for
"Waste Management".
g) On completion of backfilling; the area including walkways, access roads,
drainage etc. shall be reinstated to a condition equivalent to that before the
commencement of excavation work.
h) Excavations shall be backfilled in 150mm layers in such a manner as not
to disturb the structure, and be solidly rammed down and tamped with
proper tools made for this purpose.

6.0 Key Documents / Tools / References


HSEMS Procedure KOC.EV.008 for Waste Management
HSEMS Procedure KOC.SA.001 for Control & Use of Stepladders
HSEMS Procedure KOC.SA.004 for Permit to Work
HSEMS Procedure KOC.SA.007 for Entry into Confined Space
HSEMS Procedure KOC.SA.010 for Personal Protective Equipment
HSEMS Procedure KOC.SA.013 for Mobile Equipment
HSEMS Procedure KOC.SA.024 for Job Safety Analysis
HSEMS Procedure KOC.SA.25 for Handling of Explosive Materials, Substance and
EOD
HSEMS Procedure KOC.SA.031 for Working at Height
HSEMS Procedure KOC.SA.036 for Safe Work Practice While Working on Road
Standard Guideline KOC.S.001 for Safe Roads, Road Closure and Installation of
Display Boards/ Signs on KOC Roads
Appendix 1 - Excavation Checklist
Appendix 2 - Excavation Flowchart

7.0 Abbreviations
CO Carbon Monoxide
CO2 Carbon Dioxide

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EOD Explosive Ordinance Disposal


HSE Health Safety & Environment
HSEMS Health Safety & Environment Management System
JSA Job Safety Analysis
KOC Kuwait Oil Company
kPa Kilo Pascal
PPE- Personal Protective Equipment

8.0 HSE Records (Retention Time)


Excavation Checklist Records (1 Year)
Trench Inspection Records (1 Year)
Excavation Notification (Refer Permit to Work Procedure KOC.SA.004)

Review/Revision Log:

Review / Revision
Revision Details
Date

1st May 2008 Drafted the procedure

21st May 2008 Draft circulated among HSEMS Implementation Committee for review

15th June 2008 Reviewed & approved. by HSEMS Implementation Committee

25th August 2008 Document approved by Technical & Administrative Approvers

Clause1.0 Services added, Clause 4.4 3rd bullet rephrased, clause 4.6
retitled and 2nd bullet rephrased, Clause 5.1 - 3 bullets points added,
Clause 5.4 bullet c),d) &J) rephrased and new bullets (n), (o) & (p)
added, Clause 5.6 sub clauses renumbered, Clause 5.6.4 Bullet b) & c)
31st May 2011
rephrased, Clause 5.6.5 Referred working at height procedure , Clause
6.0 new document added, Clause 7.0 & 8.0 added to aligning with
Document Control Procedure & Added Not Applicable column on the
Checklist

Changed Procedure Title. Added sub-surface excavation to the scope.


Added definitions for good, medium and poor soil as per OSHA.
18th February 2014 Updated requirements for Fire Team notifications. Allowed the non-
closure of excavated areas in non-plant areas up to the expiry of the
work permit.

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Appendix 1
Excavation Checklist
Location:Permit No. ..
S. Not Required & to be
No
Description of Checks & Measures Yes No Applicable Remarks
reviewed
1 The proposed area of excavation is EOD cleared and certificate obtained
2 Asset owner contacted & permission / clearance obtained before excavation.
3 The proposed location checked with appropriate detectors for any underground services
4 Slit trenching to locate any underground services
5 Only manual excavation will be carried out
6 Excavation to be carried out by mechanical means only
7 Excavation to be carried out both utilizing manual & mechanical means.
8 Protection provided to control source of ignition for equipment to be used in hazardous area.
9 Earthmoving & other mechanical equipment are fixed with approved spark arrestor
10 Electrical wiring, termination joints & battery terminals of excavating machinery are safe.
11 Excavation area to be isolated partially / completely from other adjacent facilities.
Temporary supports are required for existing underground services to protect from exposure due
12
to excavation.
13 Area of excavation requires continuous Gas (flammable & toxic) monitoring.
14 Fire protection (portable or fixed) system required.
15 Staff protected from cave-ins & loose rock / soil that could roll into the excavation.
16 Excavation area is provided with safe access
Area of excavation properly barricaded and danger signs (e.g. warning tape, reflective cone, safe
17
cross over with handrail, flashing light etc.) are provided.
Area of excavation / trenches is to be protected against possible ingress of rainwater / spilled liquid
18
from adjacent facilities.
19 Excavation will not lead to water / liquid ingress through the trench into adjacent building.
20 The site of disposal for excess excavated material is determined
21 Banksman / Signalman for excavating machinery operator is required.
22 Continuous onsite supervision required during excavation work.
23 Safe detour / by-pass along with warning signs are provided as per requirement.
24 Excavated area backfilled, compacted and made as original.

Name of Worksite Supervisor: .Designation: ..Id. No. .


Controlling Team: ..Signature: ..Date ..

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Appendix 2 - Excavation Flowchart


Need for Excavation Work
(The Initiator to raise the Excavation Notification)

Endorsement of Excavation Notification


(By all concerned Teams / Groups)

Take remaining
Is endorsement No Endorsement
complete?

Yes

Apply for Appropriate Work Permit


(By Permit Applicant)

Are potential hazards identified & mitigated? No Address the


(In association with Permit Applicant & Issuer) hazard

Yes

Worksite Supervisor completes Excavation Checklist

Work Permit authorized by Issuer

Excavation work carried out safely.

Work is complete &


trenches no more needed

Backfill the trenches safely & return


the area to original condition

Site condition verified &


Permit Closed

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