CONFINED SPACE PLAN
CHAPTER CONTENT PAGE
Section 1
-Overview - Introduction
- General Responsibilities
- Definitions
Section 2 - Space Assessment and Classification
- Space
Classification
- Alternative Procedures
- List of Confined Space
and Assessments
Section 3 - Confined Space Entry Procedures
- Procedures
- Basic Permit Confined Space Entry Procedures
- Basic Alternative
Procedure Entry
Section 4 - Appendix A: Confined Space Assessment Protocols
- Assessment Steps
- Assessment/Alternative Procedures
Certification
Section 5 - Appendix B: Entry Permit Forms
- Confined
Space Entry Permit
- Alternative Procedure Documentation Form
- Hot
Work Entry Permit
Section 6 - Appendix C: Equipment Inspection
Section 7 - Appendix D: Related Safety Rules
Section 8 - Appendix E: Contractor Notification Form
Section 9 - Appendix F: Employee Training Program and Certification
Form
CONFINED SPACE ENTRY AND OPERATIONAL
PLAN
INTRODUCTION
Every employer is responsible for setting policies to properly handle work operations in confined spaces, as a result, Portland State University has established the following confined space policy and procedures. Supervisory employees are responsible to ensure that proper procedures are carried out in all phases of confined space entry operations.
Policy - No employee shall enter any confined space without the
expressed permission of his/her supervisor.
GENERAL RESPONSIBILITIES
1.PSU Facilities Services Management is responsible to see that
the overall employee work procedures and equipment meet this policy and
Oregon OSHA standards.
a. The supervisors are responsible for ensuring that the proper
safety equipment is available and used and for the safety of the
employees during confined space entry. A designated lead person may be
assigned the responsibility for directing the permit confined space
entry.
b. The entry supervisors are designated employees who have
received training on how to evaluate and control confined space
hazards. These employees shall be responsible for:
- Evaluation of all confined spaces including those that are
non-permit required to ensure that all hazards are controlled.
- Completion of the work permit indicating the safety equipment
required.
- Special precautions to be observed.
- The number of
employees permitted to enter.
- The duration of the permit.
- Cancellation of the permit.
c. The entry supervisors are responsible for maintaining copies
of all permits issued for one year. At the end of the year the entry
supervisors and Safety Committee will review the permits and conduct
the required annual program evaluation.
2. Manager of Environmental, Health and Safety
(EH&S) office is responsible to see that affected employees are
trained in this program and that the annual program evaluation is
completed. The Manager of EH&S is also available to assist Facilities
Services, Communications and other PSU staff in completing Confined
Space Assessments.
3. Safety Committee is responsible to conduct quarterly
inspection audits regarding overall facilities safety. Confined space
entry procedures and equipment should be evaluated as routine part of
the inspection activities.
4. All Employees are to follow the appropriate confined space
entry procedures and ensure that the equipment in use if performing
properly. This plan specifically addresses the following employees who
have access to confined spaces or hire outside contractors for entry
into confined spaces.
- Facilities Services Personnel: Electrical, HVAC,
Building Facilities Staff
- Communications Personnel: for purpose of entering telephone
vaults, and crawl spaces in attics or under building spaces.
The following policy defines the types of spaces that are classified
as confined spaces under Oregon OSHA "Permit Required Confined
Spaces" CFR 1910.146. Remember if you have questions about any
space please consult with your supervisor or the EH&S Manager prior to
entry.
DEFINITIONS
The following
definitions are for terms used throughout this document and are based
on the OSHA 1910.146 Permit Required Confined Space regulation
definitions.
NOTE: Additional Definitions are found in Rules.
THESE ARE KEY DEFINITIONS:
- Confined Space: means a space that:
- Is large enough and so configured that an employee can bodily
enter and perform assigned work; and
- Has limited or restricted means for entry or exit (for example,
tanks, vessels, silos, storage bins, hoppers, vaults, and pits are
spaces that may have limited means of entry); and
- Is not
designed for continuous employee occupancy.
- Permit-Required Space: means a confinedspace that has
one or more of the following characteristics:
- Contains or has a potential to contain hazardous
atmosphere;
- Contains a material that has the potential for engulfing an
entrant;
- Has an internal configuration such that an entrant could be trapped
or asphyxiated by inwardly converging walls or by a floor which slopes
downward and tapers to a smaller cross-section; or
- Contains any other recognized serious safety or health
hazard.
- Non-Permit Space: means a confined space that does not
contain or, with respect to atmospheric hazards, have the potential to
contain any hazard capable of causing death or serious physical harm.
Examples include: vented vaults, motor control cabinets, and dropped
ceilings. Although they are "confined spaces", these spaces
have either natural or permanent mechanical ventilation to prevent the
accumulation of a hazardous atmosphere, and they do not present
engulfment or other serious hazards.
- Entry: Entry into a confined space occurs as soon as
any part of the entrant's body breaks the plane of an opening into the
space.
- Entry Permit: The written permit defines the conditions
under which the permit space may be entered.
- Entry Supervisor: means the person (such as employer,
foreman, or crew chief) responsible to determine if acceptable entry
conditions are present at a permit space where entry is planned, for
authorizing entry and overseeing entry operations, and for terminating
entry as required by this section.
NOTE: An entry supervisor also may serve as an attendant
or as an authorized entrant, as long as that person is trained and
equipped as required by this section for each role he or she fills.
Also, the duties of the entry supervisor may be passed from one
individual to another during the course of the entry
operation.
- Hazardous atmosphere: means an atmosphere which exposes
employees to a risk of death, incapacitation, injury or acute illness
from one or more of the following causes:
- A flammable gas,
vapor, or mist in excess of 10% of its lower flammable limit (LFL).
- An atmospheric oxygen concentration below 19.5% or above 23.5%.
- A combustible dust environment.
- An atmospheric
concentration of any substance for which an employee exposure would
exceed the permissible exposure limit (PEL).
- Any atmospheric
condition recognized as immediately dangerous to life or
health.
- Immediately dangerous to life or health: means any condition
which poses an immediate threat of loss of life; or may result in
irreversible or immediate-severe health effects or other conditions
which could impair escape from the permit space.
- Permissible Exposure Limits (PEL): means an airborne
chemical exposure limit established by Oregon OSHA which can not be
exceeded without proper respiratory protection and the implementation
of feasible engineering controls.
Space Classification
The classification of confined spaces was based on the following OSHA
required terms and assessment procedures. The following listing shows
the general type of confined spaces found in facilities operations.
Classes
-
Permit-Required Space- means a space with an atmosphere
which exposes employees to a risk of death, incapacitation, injury or
acute illness from on or more of the following causes: flammable or
combustible gases, oxygen deficient or enriched atmosphere, toxic
atmosphere, engulfment, and other serious physical hazards. Any
welding or hot work being done in a confined space requires both a
Confined Space Permit and Hot Work Permit.
- Non-Permit confined space- means a space where there is an
extremely low likelihood that an IDLH (immediately dangerous to life
and health) or engulfment hazard could be present, and where all other
serious hazards have been controlled. The OSHA standard defines a
non-permit space as:
a confined space that does not contain or, with respect
to atmospheric hazards, have the potential to contain any hazard capable
of causing death or serious physical harm.Examples of non-permit confined spaces include:
vented vaults, motor control cabinets, and dropped ceilings. Although
they are "confined space" these spaces have either natural or permanent
mechanical ventilation to prevent the accumulation of a hazardous
atmosphere, and they do not present engulfment or other serious
hazards.
The OSHA standard does not apply to non-permit confined space so
if there are no atmospheric hazards or any other uncontrolled hazard
then requirements in the OSHA standard do not apply. IF THE CONDITIONS
IN THE SPACE CHANGE SO THAT a hazardous atmosphere could develop or
other serious safety and health hazards exist then the space must be
RECLASSIFIED AS A PERMIT-REQUIRING CONFINED SPACE.
It is critical to note that some non-permit confined space can still
be very hazardous and additional controls are needed when working
in the space. Reclassification is addressed in Appendix A Confined
Space Assessment.
- PERMIT REQUIRED SPACES THAT CAN USE Alternative Procedures
are allowed if the Person Authorizing the Permit can show the
following:
- The only hazard posed by the permit space is a potential or
actual hazardous atmosphere and that continuous force air ventilation
alone is sufficient to maintain that permit space safe for entry. This
also assures that all physical hazards such as mechanical equipment can
be safely locked-out from outside the space prior to entry.
- Person authorizing the permit has air monitoring data to
show that the air quality is safe and is maintained during the work in
the space. A written record of the testing is maintained. SEE
Certification Form in this policy.
- Since an outside standby person is not required at these entrances,
when covers are removed, the worker shall promptly have the
opening guarded by a railing, temporary cover, or other temporary
barrier that will prevent an accidental fall through the opening and
that will protect each employee working in the space from foreign
objects entering the space.
- Before the employee enters the space, the internal atmosphere shall
be tested for potential hazards. The person authorizing the
permit will determine the type of direct reading testing, but at a
minimum, it shall include oxygen deficiency and flammable/combustible
gases. Testing shall be done periodically while the employee(s) is/are
in the space.
- Continuous forced air ventilation shall be used. The air must be
from a clean source.
- If a hazardous atmosphere is detected then the entrant will
immediately leave the space and entry would only be made with an entry
permit, if changes in the space can not render it fully safe.
NOTE: This confined space policy only addresses the type
of spaces that are regulated under OSHA 1910.146 (a) Permit Required
Confined Spaces. The next pages provide an overview of the space -
please review closely. There may also be additional spaces not
identified during the initial assessments. For any other spaces
meeting this criteria, permits or alternative procedures must be used.
The additional space assessments will need to be added to this
procedure.
CONFINED SPACE LOCATION/ASSESSMENT LISTING
BASIC
HAZARD CLASS*
There are several types of common spaces that the University employees
may enter. These include:
There are also additional significant hazards when working on or in
cooling towers including proper control of hazardous energy by lockout,
fall protection needed when working on top of the towers especially
when removing the drift plates.
The following are EXAMPLES OF THESE TYPES OF SPACES. NOTE: This does
not list every possible confined space at each campus but defines the
type of space.
CONFINED SPACE LOCATION/ASSESSMENT LISTING BASIC HAZARD
CLASS
- Water Control Valve Vaults and Backflow Preventer Valve Vaults:
Examples:
-
- Manhole or Floor Plate Entrances:
Examples:
- Electrical/Telephone Equipment Vaults:
Examples:
- Tanks: Examples:
- Attic Crawl Spaces: Examples:
- HVAC and Air Cleaning Devices: Examples:
- Pipe/Plumbing Chases: Examples:
*The entry supervisor is trained in making the final space assessment. These spaces depending on work tasks are permit spaces but the "alternative procedures" may be applied due to the type of hazard and controls in place.
ENTRY PROCEDURES
- The initial step is the assessment of spaces that are
confined spaces under the OSHA rules. It must then be determined
if the spaces are permit or non-permit required. This is the on-going
responsibility of University's management to see that new facilities
are reviewed as potential confined spaces and that program changes are
added to this procedure.
- Only trained employees will perform work in confined space.
Supervisors shall ensure that only authorized employees who have
received the appropriate training are permitted to enter confined spaces.
Each affected Department will identify the employees who enter confined
spaces and ensure that the employees are trained and proficient in the
duties assigned.
- Signs shall be posted on or near permit spaces in the
facilities to notify employees what hazards may be present and that
only authorized workers may enter those spaces. Signs are not
practical nor feasible for the street type manholes thus all those
areas are automatically considered confined spaces and only authorized
employees will have access. Warning signs will be placed on interior
tank or process equipment. All manholes will automatically be
considered a confined space.
- The safety equipment to be used in a confined space must be inspected
by a qualified person designated by FACILITIES MANAGEMENT who certifies that
the equipment is in working condition as outlined by the OSHA rules or by
the manufacturer's specifications. The inspection frequency varies depending
on specific rule requirement and by the manufacturer's specifications. See
APPENDIX C Equipment Inspection Procedures.
The equipment includes, but is
not limited to:
- Ladders
- Personnel-hoists
- Safety Harness or life lines
- Gas Monitors
- Power ventilators
- Respiratory Protection Devices
- Communication systems
- A Confined Space Entry-Hazardous Atmosphere Work Permit must be
issued for each permit required confined space entry. The permit will be
properly filled out and followed. Specific Permit instructions are given in
APPENDIX B.
- The permit is required to be kept for one year. Entry Supervisors will
maintain copies of the permits and will send copies to the EH&S manager
at the end of the year to provide information for the annual review of
this policy.
- Permits may be granted for the duration of the project requiring
confined space entry. The permit is only valid as long as the physical
conditions set out in the permit are met.
- The permits are to be posted at the work area or kept in the
vehicle in use at the work site if it is not feasible due to location
or the weather to post the permit at the space.
- Testing of the air within confined spaces shall be performed
prior to entry to determine oxygen content, toxic gas potential and
flammable or explosive atmospheres.
- Entry into a confined space is prohibited until initial testing of
the atmosphere has been done from outside the space.
- The tests performed shall include those for oxygen content, flammable/
combustible gases, and hydrogen sulfide. Additional tests may be required
by the Entry Supervisor depending on the entry circumstances.
- If the space meets the criteria for ALTERNATIVE PROCEDURES then the
entry supervisor will fill out a certificate noting the evaluation and
at a minimum the following procedures would be required:
- Provide continuous ventilation.
- Provide continuous air monitoring.
- When entrance covers are removed, the opening shall be promptly
guarded by a railing, temporary cover, or other temporary barrier that will
prevent an accidental fall through the opening and that will protect each
employee working in the space from foreign objects entering the space. (Note:
this is not required if there is a standby attendant)
NOTE: No standby attendant, special rescue devices, or full permit
would be required if alternative procedures are allowed.
- If the space meets the following air quality standards then entry
may be done without a SCBA or continuous airline with escape bottle:
- Oxygen level between 19.5% - 23.5%
- Flammable vapors below 10%* (note: this level could be a significant health
risk depending on the type of vapors - any readings on combustible gas meter
will need further evaluation if an employee is entering the space
without respirator protection)
- Hydrogen sulfide below the PEL of 10 ppm
- Carbon Monoxide below the
PEL of 35 ppm
- Even under these conditions an entrant may be required to wear an air-
purifying respirator for protection against other chemicals.
- NOTE: If unusual odors are present, entry shall NOT be made until it
is determined what the source of the odor is and the potential hazard. The
presence of odors is not always related to the degree of hazard just as the lack
of odor does not mean that it is safe; however, odors could be the result of
illegal chemical dumping or an accidental spill which could affect your health
and safety. The space needs further evaluation prior to entry.
- The atmosphere with one or more of the following characteristics may be
entered only with SCBA or airlinge with 5 minute escape bottle because
the environment would be defined as Dangerous and/or IDLH. It is the
University's policy to ventilate, purge, and clean confined spaces
until such time the atmosphere is below dangerous levels.
- Oxygen levels below 19.5% (never enter oxygen enriched environment
equal to or greater than 23.5% oxygen
- Flammable vapors below 10% LFL - No one shall enter a potentially
explosive environment (over 10% LFL).
- Hydrogen sulfide above the PEL of 10 ppm.
- Carbon Monoxide above the PEL of 35 ppm.
- Other hazardous air contaminates in excess of the permissible exposure
limits
- Where a confined space cannot be purged and ventilated to provide
and maintain a safe atmosphere, then a worker entering a confined space shall
use all of the following:
- A self-contained breathing apparatus (SCBA) or a continuous air-line system
with a 5 minute escape bottle.
- Continuous air monitoring to ensure levels are below 10% LFL.
- A safety harness of a type which will keep the worker in a position
to permit rescue. Where feasible the harness line should be attached to
the mechanical hoisting device.
- A life line attached to the safety harness which is tended by the outside
attendant.
- A spare SCBA, life line and harness and additional staff must be available
for rescue if a tripod device is not able to be used because of the
configuration of the space.
- Ventilation of confined spaces shall be used to provide adequate levels of
oxygen, to dilute toxic and flammable gases and to improve general air quality. The ventilation
equipment shall be explosion proof if it is placed inside the confined
space.
- The Material Safety Data Sheets (MSDSs) of all products
and cleaning materials used in confined space must be reviewed before
entry unless the products have already been covered with the employees
in the routine hazard communication training. The MSDS must be
available with the permit at the permit-required confined space entry
area.
- Mechanical and electrical equipment installed in the confined space must
be disconnected from its power source and locked out. Our lock-out program
must be followed (See: Energy Control Plan - Lock-out Policy for further
details).
- Only double insulated electric tools or tools on a ground fault circuit
interrupter system are used in confined spaces.
- All portable lights and tools shall be explosion proof when working in a
confined space where there is a potential flammable or explosive atmosphere.
- The Entry Supervisor is to ensure that the proper procedures and equipment
necessary to rescue an entrant from a permit space are implemented and
provided. This includes:
- Safety harness, life line and tripod hoist or other type of rescue devices
as needed for the permit space being entered which are a vertical entrance of
more than 5 feet.
- Communication with other entry team members by Mobile Radio, Telephone or
other effective means is provided.
- First aid and emergency response by notification of the University first
aid/CPR trained member and 5-4404 (Security) rescue assistance.
- The Entry Supervisor is to ensure that all pedestrian, vehicle or
other barriers necessary to protect workers from external hazards are
provided when the space is in traffic areas.
- When any hot work involving sources of ignition includin welding
and burning is done in a confined space, then all fire hazards and
flammable atmospheres must be controlled. All combustible material
shall be protected. Hot work permit and instructions are found in
Appendix B. These procedures are in addition to the general Hazardous
Atmosphere Permit Entry requirements.
- Many other occupational safety regulations relate directly or indirectly to
conditions found in confined spaces. Appendix D provides a listing of possible
related issues and the rule references. If you have any questions about these
other safety issues please contact the entry supervisor.
- When the University hires an outside contractor to conduct confined
space work then the PSU Department management responsible for the
contract work must insure that the contractor is provided with
information about the hazards associated with the confined spaces
involved in the contract - See Appendix E.
- The following procedures provide the minimum required for preparation and
entry steps into a permit required space. Remember each entry needs to be
evaluated and the specific conditions for the entry are to be based on
hazards of the space and the type of work procedures.
BASIC PERMIT-REQUIRED CONFINED SPACE
ENTRY
PROCEDURES
TYPE OF SPACES: PERMIT - REQUIRED
- Manholes: water, sewages, and storm manhole access
- Vaults/Pits
Equipment Required:
The following equipment is required to be with each crew performing confined
space entries:
- Gas monitor
- Power ventilator
- Appropriate respirators as needed, which may include airline respirator
system or self contained breathing apparatus (SCBA)
- Safety harness
- Personnel-lift (hoist) - required for vertical enters of more than 5 feet.
- Personal Protective Equipment including but not limited to: Hard Hat,
Coverallsor other Protective Clothing, Gloves, Half Face Respirators with
Chemical and Particulate Cartridges
- Mobile Radio or communication system
Personnel
A minimum two person crew is required. If the space and entry are difficult
more employees may be needed because of the complexity of work and potential
problems encountered when performing maintenance and repair. This includes
extended entry times in manholes and vaults, chemical product usage,
extensive equipment to use and handle, and often difficult traffic
routing and control issues.
Procedures
Step 1
Permit
The "Entry Supervisor" fills out the Entry Permit noting the
specific requirements to be followed. Those requirements will include the
following steps.
Step 2
Testing
Monitor
the manhole or space atmosphere with the gas detector. Record the
levels on the permit and continually monitor while the space is open.
If the monitoring indicates an unacceptable atmosphere after either
ventilating or waiting for a short time period the entry supervisor
needs to be notified. An acceptable atmosphere is defined on the
permit. If the atmosphere is not acceptable then employees are
NOT PERMITTED TO ENTER THE SPACE AND THE PERMIT WOULD NOT BE
VALID.
Step 3
Ventilate
Ventilate
with power ventilator of at least 750 CFM capacity or more. Ventilate until
the atmosphere is safe to enter and continue to ventilate while the manhole is
open.
Step 4
Rescue Device and Access
For Manholes and vaults with vertical
entrance of more than 5 feet a personnel lift needs to be set up.
Examine and inspect all the lines to ensure that they are functioning
properly. For horizontal entrances have the employee in safety harness
and life line. If the space requires portable ladders or other
entrance devices those will be made available and be in proper working
condition.
Step 5
Communication
The employees discuss and determine
communication methods prior to manhole or vault/tank entry. Emergency
rescue procedures need to be determined and communicated with the
entrant(s) and standby employees.
Step 6
Respirator
If
necessary*, set up the breathing air supply system and inspect air
supply system components to ensure proper function. Place the system
in an area readily available to the work space.
Air line supply system is defined as: full face mask, 5-minute hip pack
for emergency escape, and the remote air supply cylinder and hose line
or a self contained breathing apparatus (SCBA).
*NOTE: In most cases entries are only permitted if the space atmosphere
is acceptable. There are conditions, however, where the work will
involve the use of paints, other chemicals, and welding that would
require proper respiratory protection. This must be determined and
stated on the permit based on the hazard.
Step 7
PPE
The employee
entering puts on the safety harness, gloves, hard hat, and is secured
to the personnel-lift. Don the respiratory protection if needed.
The employee will generally wear the gas monitor, if not, the standby
employee will monitor the atmosphere with a remote probe in the area
where the entrant is working.
Step 8
Standby Duties
When the standby employee topside is prepared,
check gas monitor, and personnel-lift. After all the equipment is
checked then the employee can enter into the space. The topside
employee will continuously check the gas monitor if the employee is not
wearing the monitor or other personnel air monitors.
Step 9
Standby Duties
While the employee is in the manhole, the
standby employee remains alert to his/her activity. Mobile radio
source must be within 50 feet of the manhole work. If gas monitor
alarm activates, employee will signal the entrant and the entrant is to
leave the space.
Step 10
Exiting
When
the work is completed the entrant employee will signal topside
observer(s) who will operate man-lift and life lines to ensure none
become entangled with obstructions.
GENERAL ALTERNATIVE PROCEDURE CONFINED
SPACE
ENTRY PROCEDURES
TYPES OF SPACE WHERE ALTERNATIVE PROCEDURES MAY APPLY
INCLUDE:
- Vaults containing: water control valves, meter boxes, pump stations,
backflow (double check) valves, fire protection system valves.
- Pits/Sumps: containing sump pumps, condensate drain, other equipment
- Tanks and Reservoirs: Truck mounted tanks, process tanks (water
treatment plant)
- HVAC units and duct work (normally non-permit spaces
Equipment Required
- Gas monitor
- Power ventilator
- Personal Protective Equipment including but not limited to: hard Hat,
Coveralls or other protective Clothing, Gloves, Half Face Respirators with
Chemical and Particulate Cartridges
- Proper manhole or hatch entrance cover guarding
Personnel
If a space is classified as a permit space allowing alternative procedures then
only one employee can enter and work alone. If the space cannot be made safe or
there are more hazards than atmosphere only the space must be classified as
permit requiring with at least two employees involved. If the space and entry
are difficult more employees may be needed because of the complexity of work and
potential problems encountered when performing maintenance and repair.
Procedures
Step 1
The "Entry Supervisor" fills out the alternative procedure
form noting the space test data. This data may be used from previous
entry with the employee noting test results on alternative procedure
form (See Appendix B).
If Alternative Procedure can safely be used, Oregon OSHA does not require
a full permit, standby attendant, or emergency rescue procedures to be implemented.
The space must be maintained in safe condition and if test data shows a change
that could be hazardous then the employee must immediately leave the
space.
Step 2
Cover Removal
Remove the hatch or manhole covers safely and install a portable barrier
if a second person is not stationed outside the confined space.
Step 3
Ventilate
Ventilate with power ventilator of at least 750 CFM capacity or more.
Ventilate until the atmosphere is safe to enter and continue to ventilate while the
manhole is open. Continuous forced air ventilation shall be
used. The air must be from a clean source.
Step 4
Testing
Monitor the confined space atmosphere with the gas detector. Record
the levels on the certification form. If the monitoring indicates an unacceptable
atmosphere after either ventilating or waiting for a short time the supervisor needs
to be notified.
If the atmosphere is not acceptable then employees are NOT ALLOWED
TO ENTER THE SPACE AND A PERMIT WOULD NEED TO BE ISSUED.
Step 5
PPE
BLOCKQUOTE>The employee entering puts on required safety equipment. The employee
will generally wear the gas monitor.
Step 6
If a hazardous atmosphere is detected then the
entrant will immediately leave the space and entry would only be made with an
entry permit, if changes in the space can not render it fully safe.
APPENDIX A - CONFINED SPACE ASSESSMENT
CONFINED SPACE ASSESSMENT WORKSHEET:
The confined space assessment worksheet will be done by our
trained entry supervisors. Space characteristics and controls may change
as a result a space may be initially documented as a permit space and
then need to be reclassified. Department Management must keep
documentation on the space change in a form of a certification form
enclosed. The following form provides documentation for the assessment
of non-permit space for reclassification.
The following information must be gathered and recorded. The evaluator
must also sign the assessment sheet and make sure that this is available
to employees entering the space.
The initial step in assessing a space is to determine if the space is a
"confined space" then to assess the space as to whether it is
permit-required or non-permit. It is critical that the assessor uses
Oregon OSHA's definition for each of these types of spaces in making the
determination:
Step 1: Confined Space Determination
- Is large enough and so configured that an employee can bodily enter
and perform assigned work; and
- Has limited or restricted means for entry or exit (for example,
tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces
that may have limited means of entry); and
- Is not designed for continuous employee occupancy.
Step 2: Non-permit Space
Non-permit confined space - means a space where there is an
extremely low likelihood that an IDLH (immediately dangerous to life and
health) or engulfment hazard could be present, and where all other
serious hazards have been controlled. The OSHA standard defines a
non-permit space as:
"a confined space that does not contain or, with respect
to atmospheric hazards, have the potential to contain any hazard capable of
causing death or serious physical harm."
Examples of non-permit confined spaces includes: vented vaults,
motor control cabinets, and dropped ceilings. Although they are
"confined space" these spaces have either natural or permanent mechanical
ventilation to prevent the accumulation of a hazardous atmosphere, and
they do not present engulfment or other serious hazards.
Step 3: Permit Required
Permit-Required Spaces: means an atmosphere which exposes
employees to a risk of death, incapacitation, injury or acute illness
from one or more of the following causes: flammable or combustible
gases, oxygen deficient or enriched atmospheres, toxic atmospheres, engulfment,
and other serious physical hazards.
These type of spaces will have limited or restricted means for entry or
exit. Examples given in the regulations include tanks, vessels,
silos, storage bins, hoppers, vaults, pits and diked areas. These
spaces are also not designed for continuous employee occupancy.
Step 4: Determining Need for Hot Work Permit
Hot Work Permit: Any welding or hot work being done in a confined
space requires both a Confined Space Permit and Hot Work Permit
even if the confined space is originally defined as Non-permit.
Step 5: Reclassification of Permit Space to Alternative or
Non-Permit
A space can be reclassified as non-permit space under the following
conditions:
- If the permit space poses no actual or potential atmospheric hazards
and if all hazards within the space are eliminated without entry into the
space, then the permit space may be reclassified as a non-permit
space.
- If testing and inspection during a permit entry demonstrate that the
hazards within the permit space have been eliminated, the permit space
may be reclassified.
- The Department must document this determination.
- If hazards arise within a declassified space then the employees shall
exit and a permit will be required with appropriate safeguards.
CONFINED SPACE - ASSESSMENT WORKSHEET
DOCUMENTATION OF CONFINED SPACE ASSESSMENT AND
CLASSIFICATION FOR ALTERNATIVE PROCEDURES
- Potential Confined Space and Specific Location:
________________________________________________________________________
________________________________________________________________________
- Reasons for Entry and how frequent:
________________________________________________________________________
________________________________________________________________________
- Is there a potential hazardous atmosphere? If not why?
________________________________________________________________________
________________________________________________________________________
- List other potential hazards:
________________________________________________________________________
________________________________________________________________________
- Who last entered and why? Any comments on possible problems during
the entries?
________________________________________________________________________
________________________________________________________________________
- Specific Conditions of the Space and Space Test Data:
________________________________________________________________________
________________________________________________________________________
SPACE CLASSIFICATION: This space meets the following
requirements: (Note if the space is classed as IDLH/Dangerous then a
permit must be issued.)
PERMIT__________ ALTERNATIVE PROCEDURES___________
NON-PERMIT_________
Safety Officer/Entry Supervisor
_______________________________
Date
_______________________________
APPENDIX B: ENTRY PERMIT FORMS AND
EXPLANATION
Confined Space Entry Permit Forms
A written permit is necessary because of the special precautions that
must be taken to ensure that the confined space work is performed safely. The
permit functions as a checklist to ensure proper work preparation and
atmospheric testing. The permit establishes expiration time and date
which prevents the entry permit from being used for unauthorized entries.
The permit also requires signature of the responsible supervisor/lead
person in charge and employees who will perform the work.
There are 2 permit forms:
- Confined Space Entry Permit - The permit requires that the
entry be evaluated for safety and health hazards and necessary controls.
- Hot Work Permit to be used with the Confined Space Entry
Permit which addresses the additional hazards from welding and other hot
work.
Confined Space Permit Entry Instructions - The Permit form
includes the following information:
- The identity of the permit space or location of work.
- The purpose of entry (nature of job being done).
- The individual authorizing the entry shall sign the permit before the
entry begins. Entry is not permitted until all actions and conditions
necessary for safe entry have been performed (on-site supervisor).
- Special instructions prior or during entry.
- Space classification. Note if the space is determined not to be a
confined space a record should be made and noted on the form.
- The measures for isolation of hazardous energy sources in the permit
space which includes lock-out procedures to be performed.
- Type of hazardous work being performed which takes additional
precautions including: painting, sand blasting, electrical work, welding,
etc. If hot work is required then the Hot Work Permit will also be
required.
- Special precautions that will be needed including procedures for
purging, inerting, ventilating and flushing the space to remove or
control the potential hazards.
- The communication procedures and equipment used by authorized workers
and attendants to maintain contact.
- Rescue procedures, equipment, and other services which would be
summoned in case of emergency and means of communication with those
services.
- The personal protective equipment, such as: hard hats, gloves,
coveralls, respirators, safety harness, and retrieval lines, provided in
order to ensure employee safety.
- Acceptable environmental conditions with regards to the hazards
identified in the permit space by monitoring the air quality.
- The date of entry and authorized duration.
- The authorized confined space workers' signatures.
- Upon completion of the entry covered by the permit, and after
all workers have exited the permit space, the individual authorizing the
entry shall cancel the permit.
NOTICE
In the event that toxic/flammable gases in a confined space cannot be
reduced below acceptable levels as posted on the procedures, no one shall
enter except when using proper equipment including SCBA unit or
air-supplied respirator.
APPENDIX C: EQUIPMENT INSPECTION PROCEDURES
Requirement
The safety equipment used in a confined space must be inspected by a
qualified person designated by our management staff. The inspection
evaluates the equipment to ensure that it is functioning as required by
the OSHA rules or by the manufacturer's specifications. The inspection
frequency varies depending on specific rule requirements and on the
manufacturer's specifications.
OSHA has specific inspection and/or maintenance rules for ladders and
respiratory equipment. General standards that require an employer to
assure a safe workplace and that equipment be in "good repair" would
apply to other devices used in the workplace. However for specific
inspection protocols the manufactuer's specifications or ANSI standards
will need to be used for the personnel-lift (hoist), safety harness, gas
monitoring equipment, power ventilators, and communication systems.
Inspection Log
Our employees inspecting the equipment will use an inspection log to keep
track of the equipment condition and ensure that all the relevant items
are evaluated.
INSPECTION PROTOCOLS:
Ladders - The Oregon OSHA rules have specific care, maintenance and
inspection procedures for ladders dependent on the type of ladder
Portable wood or metal and fixed fixtures.
- Portable Wood Ladders:
Wood ladders are to be free from sharp edges and splinters. Upon
inspection the ladders are not to shake, or wane. The ladder is not to
show any compression failures, decay or other irregularities. (Rule
#1910.25(b)(1)(i))
The specific care and maintenance includes: (Rule #1910.25(d)(i)-(xi).
- Ladders shall be maintained in good condition at all times, the joint
between the steps and side rails shall be tight, all hardware and
fittings securely attached, and the movable parts shall operate freely
without binding or undue play.
- Metal bearings of locks, whells, pulleys, etc., shall be frequently
lubricated.
- Frayed or badly worn rope shall be relaced.
- Safety feet and other auxiliary equipment shall be kept in good
condition to insure proper performance.
- Ladders shall be inspected frequently and those which hae developed
defects shall be withdrawn from service fo rrepair or destruction and
tagged or marked as "Dangerous, Do Not Use".
- Rungs should be kept free of grease and oil.
- Portable Metal Ladders:
The maintenance and care of portable metal ladders includes:
- Ladders must be maintained in good usable condition at all times.
- If a ladder is tipped over or damaged then an immediate inspection is
necessary, which includes:
- Inspecting the side rails for dents, or bends, or excessively dented
rungs;
- Checking all runt-to-side-rail connections,
- Checking hardware connections and the rivets for shear;
- If ladders are exposed to oil and grease, equipment should be cleaned
of oil, grease or slippery materials.
- Fixed Ladders:
Fixed ladders are required to be protected from deterioration. This
includes:
- Metal ladders and appurtenances shall be painted or otherwise treated
to resist corrosion and rusting when location demands.
- Ladder rungs in a corrosive atmosphere shall be a minimum diameter of
1 inch or shall be painted or otherwise treated to resist corrosion that
is maintained in good repair.
Fixed ladders are to be maintained in a safe condition, and all ladders
shall be inspected regularly, with the intervals between inspections
being determined by use and exposure. (Rule 1910.27(f))
- Respirators
SCBA's and airline systems used routinely are to be checked after each
use. Those used for emergency or infrequently need to be checked
monthly. The checks are to assure that the equipment is kept clean and
in proper working condition. The respirator inspection shall include an
evaluation of:
- Tightness of the connections
- Condition of the face piece
- Condition of the headbands
- Condition of the cartridges or tank pressure
- Condition of the valves
- Pliability and cleanliness of the face piece material
FOR FURTHER DETAILS SEE RESPIRATORY PROTECTION PROGRAM
- Fall Protection
Fall protection and safety harness or life lines are currently only
mentioned in OSHA's Confined Space regulations and specific inspection
and maintenance requirements are not given. The exception to this is found
in the new Powered-Platform Lift Rules which do provide specifications.
While those rules only apply to powered platforms they do provide
guidelines for the types of systems, inspection and maintenance programs
for these pieces of equipment.
APPENDIX D: RELATED SAFETY RULES
SAFETY ISSUE OSHA RULE#
Access and Egress (Work Surface) 1910.37
Air Contaminants - PELs 1910.1000
Electrical Safety 1910.301
Emergency Plans & Rescue Protocols 1910.38
Fire Protection 1910.157
First Aid 1910.151
Hazard Communications 1910.1200
Hazardous Materials Spill Response 1910.120
Hot work permits 1910.146 and
1910.252 (c)(6), (d)(2)
Ladders: Fixed 1910.34
-Portable metal 1910.26
-Portable wood 1910.25
Lock-out/Tag-out 1910.147
Machine Guarding 1910.211-.222
PPE & Hygiene Facilities 1910.132
-General PPE
Respiratory Protection
-General 1910.134
-Medical Monitoring 1910.134
Safety Harness 1910.252(e)(4)(iv),
-Fall Protection 1910.27(d)(5)
Signs & Tags 1910.145, .1001
Tools 1910.241, .243
Traffic Control Uniform Traffic Control Devices
APPENDIX E: CONTRACTOR NOTIFICATION FORM
The
contractor notification will be done by the University's
Project Manager and/or Supervisor. This notification is to ensure that
the company complies with rule 1910.146(c)(8) of the Confined Space
regulations. If the University contracts for confined space entry work
as the host employer the Department doing the hiring is responsible
to:
- Inform the contractor that a permit required space is involved in the
work. This includes information about any chemicals in the space per
Hazard Communication requirements.
- Apprise the contractor of the hazards the University has identified
and any experience the University's employees have had with the space.
- Apprise the contractor of any precautions the University's employees
have taken for entry.
- Coordinate entry operations with the contractor if more than one
contractor or if the University's employees will also be entering the
space.
- Debrief the contractor to determine if any problems were encountered
requiring changes in procedures.
APPENDIX F: EMPLOYEE TRAINING PROGRAM
Objectives
Employees who are required to work in a confined space, or in support of
those working in a confined space shall have the following training:
- Understand the hazards associated with confined spaces.
- General hazards and the specific hazards for each confined space
that will be entered.
- Recognition of the signs and symptoms of exposure to a hazard and the
consequences of the exposure.
- How the communications will be maintained between the attendant and
the workers in the confined space.
- Emergency entry and exit procedures
- Use of respirators and other protective equipment
- First aid and CPR
- Lockout and isolation procedures
- Safety equipment use
- Rescue procedures
- Permit system
- Work practices required under the permit
Supervisor Training
The individual in charge or authorizing the entry shall have additional
training on how to evaluate the confined space ensuring that the permit
calls for adequate safeguards. This individual needs to know how to use
the testing and monitoring equipment and all other aspects of the entry
program. This additional training will be arranged by our Management
including arrangements with equipment manufacturer's training
programs.
Training Certificate
The University will use the training certificate as shown on the next
page which contains the name of each employee trained, the signatures of
the trainer(s), and the date of the training.
Training Frequency
Training frequency required by the Oregon OSHA standard is:
- Before the employee is first assigned duties involving confined
space.
- Whenever there is a change in permit space operations that presents a
hazard about which an employee has not previously been trained.
- Whenver there are deficiencies in the program and/or employee
performance relating to the safety of the confined space entry.