CONFINED SPACE PROGRAM

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CONFINED SPACE PROGRAM

• 29 CFR 1910.146

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What is a Confined Space?
A space that

• Is large enough and so configured that an
  employee can enter bodily and perform work
• Has limited or restricted means of entry or exit
• Is not designed for continuous human occupancy.

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Examples of Confined Spaces

• Tanks
• Manholes
• Boilers
• Furnaces
• Sewers
• Silos
• Hoppers

• Vaults
• Pipes
• Trenches
• Tunnels
• Ducts
• Bins
• Pits

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HAZARDS (1)

• Atmospheric Lack of sufficient Oxy
• Excessive Oxy levels Fire/Explosion
• Flammable/Combustible
• Toxic
• Electrical/Mechanical
• Engulfment/Entrapment

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Human Factors

• Ignoring directions from supervisors
• Improper use of PPE while angry/distracted
• Distracted due to personal problems
• Not following procedures/taking shortcuts
• Drowsy/fatigued due to medication, drugs alcohol

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RESPONSIBILITIES (2)

• Installation Safety
• Installation Fire Chief
• Commander and (or) Functional Mgrs.
• Entry (On-Site) Supervisor
• Entrant
• Attendants

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Installation Safety

• Focal point for implementation
• Coordinate Program
• Maintain CS records
• Verify all efforts have been made to reduce
  hazard classification of space

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Installation Fire Chief

• Provide rescue support for all CS entries to
  include contractors
• Insure members are trained, formally or
  informally
• Assist functional mgrs. in obtaining training
• Assist in ID and selection of all equipment
• Review and approve non-routine entry permits not
  contained in MEP

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Functional Managers

• Ensure written CS program is developed
• Ensure all personnel who are assigned CS duties
  are trained, equipped, and qualified and that
  training is documented.
• Ensure proper equipment is procured
• Ensure a current list of permit/no-permit spaces
  under control of function is maintained. Provide
  a copy to Safety, and Fire Department.
• Designate entry supervisors
• Review all non-permit spaces annually to ensure
  that conditions havent changed.

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Entry (On-Site) Supervisor

• Maintain organizational MEP
• Issue entry permits consistent with MEP
• Revoke permit/contact Safety when conditions
  arent consistent with MEP
• Determine acceptable conditions present where
  entry is planned
• Ensure qualified person evaluates classifies CS
• Coordinate assistance from Safety and Fire
  Department as required

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Entry (On-Site) Supervisor Cont.

• Ensure workers are properly trained qualified
  in emergency procedures, PPE, and how to egress.
• Ensure workers are healthy prior to entry.
• Brief workers on all hazards
• Inspect work area, tools, and equipment to ID and
  correct hazards
• Select appropriate PPE and ensure its
  availability at all times for entry
• Ensure respiratory equipment is in safe operating
  condition, and personnel are properly trained in
  it use.

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Entry (On-Site) Supervisor Cont.

• Ensure all power sources and equipment meet
  safety requirements. Ensure all energized sources
  are locked out.
• Ensure all valves are isolated, locked out, and
  blinded or blanked
• Establish emergency rescue procedures in the
  event of incapacitation.
• Be last person to sign permit after all
  conditions were met
• Provide an attendant for each permit entry
• Provide protection in the way of guards, barriers
  etc.

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Entry (On-Site) Supervisor Cont.

• Determine source of suspected hazardous
  conditions found at time of entry.
• Revoke entry permit, terminate entry, and secure
  site upon awareness of unexpected condition.
• Ensure a new permit is issued prior to re-entry

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Confined Space Entrants

• Fully understand all entry procedures,
  safeguards, and emergency egress/rescue
  procedures
• Follow all safe work procedures required by
  supervisors, Safety, and Fire Department.
• Notify entry supervisor when hazards exist
• Notify entry supervisor if ill or on any
  medication

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Confined Space Attendants

• Maintain accounting (who number) in the permit
  space
• Remain outside space not attempt rescue until
  rescue team arrives. Make rescue efforts by means
  of lifeline until assistance arrives
• Maintain continuous communication with all
  entrants
• Have authority to order entrants out of CS if
  conditions warrant
• Know all emergency procedures and have the means
  to summon assistance.

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Confined Space Attendants Cont.

• Remain at your post and leave for no reason
  unless replaced by equally qualified individual.
  If you have to leave you must evacuate the space
• Keep unauthorized persons from entering space

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GENERAL REQUIREMENTS (3)

• CS Program Responsibilities
• ID of CS
• Initial Testing Evaluation of CS Conditions
• Classification of CS
• Posting Signs
• Testing of CS
• Calibration of Monitoring Equipment
• Atmospheric Monitoring

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Responsible Person

• The person directly responsible for the work
  being performed in the confined space. This can
  be the Team Leader, Foreman, journeyman, or other
  person qualified by training and experience.

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CS Program Responsibilities

• Installation Safety is responsible for
  coordinating the CS program with DPW
• Each organization having tasks requiring entry
  into CS is primarily responsible for its related
  portions of the CS entry program

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Identification of CS

• The functional manager in coordination with
  Safety and Fire Department will identify,
  evaluate, and classify each CS within their
  organization
• If permit-required confined spaces are identified
  then functional manager must have a written
  program

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Initial Testing Evaluation of CS Conditions

• Functional managers and entry supervisors, in
  coordination with the Safety and Fire Department
  must test for and evaluate many factors prior to
  classifying a CS or enclosed space

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Initial Testing Evaluation of CS Conditions
Cont.

• Contents of space Flammables, Toxins,
  Oxy-deficient/enriched atmospheres
• Location Configuration of space
• Potential hazards from external environment
• Types of operations conducted within the space
• Fixtures, devices, or equipment within the space
• The presence of other hazards
• Boundary spaces and their contents

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Initial Testing Evaluation of CS Conditions
Cont.

• Initial testing will be performed from outside
  the space. Interior testing will be performed by
  drop tests or insertion of probes/hoses into
  space. Testing will be performed in the following
  sequence
• Oxygen content
• Flammable Hazard
• Toxic Materials

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IDLH

• IMMEDIATELY DANGEROUS TO LIFE OR HEALTH
• Any condition which poses an immediate threat to
  the health of life on an entrant, or
• Would cause irreversible adverse health effects,
  or
• Would interfere with an individuals ability to
  escape unaided from a permit space.

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Classification of CS

• CS classified on basis of measurements of oxygen
  content, flammability, and toxicity by testing.
• Permit-required CS may contain hazards that
  present a situation that is IDLH.
• Non-permit CS contains NO hazardous atmosphere,
  has NO engulfment potential, and is NOT
  configured in a way that could cause entrapment
  or asphyxiation
• PERMITS SIGNS ARE NOT REQUIRED FOR NON-PERMIT
  CS SITUATIONS!

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Posting Signs

• If there are CS designated as permit-required and
  personnel have the potential to enter, supervisor
  ensure all personnel are informed of the
  existence, location, and danger of the permit
  space by posting danger signs.
• DANGER PERMIT-REQUIRED CONFINED SPACE, DO NOT
  ENTER!
• (Or a commercially available equivalent that
  conforms to specifications design established
  in OSHA Regulations)
• CS where personnel cannot enter, need not be
  posted

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Approved Equipment

• Before purchasing equipment to support CS entry
  program, coordinate with appropriate member of
  Fire Department
• Supervisor will ensure testing/monitoring
  equipment approved for Class 1, Division 1, and
  appropriate atmosphere (NFPA 70)
• Only direct reading equipment with current
  calibration will be used
• Supervisor ensures equipment meets required
  safety standards (i.e. NRTL, UL)

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Testing of Confined Space

• A.k.a. verification testing accomplished prior
  to entry in permit-required CS
• Testing done by qualified person who is trained
  and certified.

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Calibration of Monitoring Equipment

• Equipment shall be calibrated by Testing,
  Measurement, Diagnostic, and Evaluation (TMDE)
  Lab Interval established by TMDE tech orders or
  manufacturers instructions
• Equipment that cannot be calibrated by TMDE shall
  be sent to manufacturer for calibration
• Equipment that comes with manufacturer-approved
  calibration devices is acceptable
• User will field check equipment prior to entry
• Workers will not use equipment that cannot be
  calibrated, and will not enter CS until repaired
  and calibrated

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Atmospheric Monitoring

• Frequency and type of testing dependent upon
  prevailing conditions and nature of operations
• Entry supervisor will establish frequency and
  types of tests and shall enter those requirements
  on MEP and the entry permit
• Continuous monitoring of oxy, flammable vapor,
  and toxicity levels should be considered for all
  permit-required operations.

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• PERMIT-REQUIRED
• CONFINED SPACE
• Characteristics
• Immediately dangerous to life or health
• (IDLH). Potential for or has contained a
• hazardous atmosphere.
• Oxygen
• Less than 19.5 or greater than 23.5
• Flammability
• Greater than 10 Lower Explosive
• Limit (LEL)
• Toxicity
• An atmosphere concentration of any
• chemical substance over the
• occupational exposure limit (OEL) which
• Is capable of causing death,
• incapacitation, impairment of ability to
• self-rescue, injury, or acute illness due to
• its health effects

• NON-PERMIT
• CONFINED SPACE
• Characteristics
• No hazardous atmosphere with no
• Creditable potential for a hazardous
• atmosphere, engulfment, or entrapment
• Oxygen
• 19.5 - 23.5
• Flammability
• Less than or equal to 10 Lower
• Explosive Limit (LEL)
• Toxicity
• An atmosphere concentration of any
• chemical substance regardless of
• occupational exposure limit (OEL) which
• Is not capable of causing death,
• incapacitation, impairment of ability to
• self-rescue, injury, or acute illness due to
• its health effects

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Permit-Required Confined Space Entry Procedure

• Isolate the space
• Ventilate the space
• Conduct Tailgate Meeting
• Complete permit
• Test the atmosphere
• Enter the space

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Isolate the Spacefrom all hazards

• Close Valves
• Double block bleed, or
• Blank flange
• Empty the Space
• Depressurize, vent drain
• Lockout/Tagout Equipment
• Electrical sources
• Rotating/reciprocating parts
• Hazardous materials
• Clean residue from the space

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Ventilate the Space

• Use mechanical ventilation
• Fans
• Air horns
• Ventilate at the rate of at least four (4)
  volumes per hour
• Larger spaces require more ventilation
• Make sure air supply is not contaminated
• Ventilation air supply must be from fresh air
  uncontaminated with flammables, toxins, etc.

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Conduct a Tailgate Briefing

• Entire crew must attend
• Attendants, entrants, entry supervisor
• Review hazards of entry and work
• Review PPE
• Review procedure for contacting rescue
• verify rescue available
• Complete permit

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Complete Entry Permit Form

• Permit must be correctly and completely filled
  out prior to entry.
• Permit must be activated by Entry Supervisors
  signature to be valid.
• No entry is allowed without a valid permit.
• Permits are valid for up to 12 hours.
• When work is completed, permit and tailboard form
  should be returned to safety.
• Cancelled permits must be kept on file for at
  least one year.

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Test the Atmosphere
In this order

• Check for Oxygen Content
• At least 19.5 and less than 23.5
• Check for Combustibles
• Less than 10 of the LEL
• Check for Toxic Gasses
• Most commonly carbon monoxide (PEL lt35 ppm)
• or any other hazardous materials as determined by
  the use of the space.

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NOTICE

• Any time a limit is exceeded, no matter what the
  reason, all personnel shall immediately exit the
  space, and no others shall enter until
  atmospheric conditions are returned to safe
  levels.

THERE ARE NO EXCEPTIONS TO THIS!
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Atmosphere Testing Shall Be Performed

• Prior to every entry when the space is vacant
• After a 10 minute ventilation period (if
  ventilation is necessary)
• At least hourly for permit-required confined
  spaces.
• More frequently, if conditions or suspicions
  warrant.

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Always test the air at various levels to be sure
that the entire space is safe.
Good Air
Poor Air
Good air near the opening does NOT mean there is
good air at the bottom!
Deadly Air
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Enter the Space and Proceed with work

• An attendant shall be posted near the entrance
  for the duration of the work. He shall be in
  constant communication with the entrants while
  the job is in progress.
• All entrants shall sign the sign in log when
  entering the space and sign out when exiting.
• The attendant shall maintain the permit and sign
  in log for the duration of the work.

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Non-Permit Confined Space

• A confined space that does not contain or, with
  respect to atmospheric hazards, have the
  potential to contain any hazard capable of
  causing death of serious physical harm.

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Non-Permit Confined Space Entry

• Isolate the space
• Ventilate the space
• Evaluate the space
• Test atmosphere
• Assure justification conditions are met
• Conduct tailboard
• Enter the space

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Enter the Space and Proceed with work

• If non-permit conditions change during the job,
  the space shall be immediately evacuated, and
  re-classified as a permit-required confined
  space or conditions shall be returned to
  non-permit conditions and again certified as such
  by the entry supervisor.

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When the Job is Done

• Remove all personnel, tools, and debris from the
  space. Sign off the log.
• Close the space.
• Cancel the permit.
• Review the job with the host employer (hazards,
  problems, other employers, etc.)

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EMERGENCY RESCUE PROCEDUES (4)

• Responsibilities
• Inspection of Safety Equipment

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Responsibilities

• The MEP will include emergency and rescue
  procedures consistent with the nature of each
  known operation that requires entry into
  permit-required CS.
• Entry supervisor will coordinate with Safety,
  and Fire Department when required to enter
  non-routine permit-required CS not included in
  MEP, and establish emergency rescue procedures
  prior to entry
• Three means of rescue self-rescue, a centrally
  located rescue team, and organizational rescue
  team

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• Self-Rescue Employees are trained to exit from
  the CS according to requirements
• Centrally Located Rescue Team According to
  local agreements, the installation fire
  department will provide rescue services
• Organizational Rescue Team When CS work is
  performed outside the installation or area where
  fire department is unable to support the
  operation.
• Will meets training requirements of entrants
• Will be CPR trained
• Appropriate Fire Department member will assist in
  selection of equipment

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Inspection of Safety Equipment

• Entry supervisors will ensure the inspection,
  testing, maintenance, and documentation of safety
  and rescue equipment are accomplished according
  to OSHA regulations.

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TRAINING (5)

• Entrants
• Entry Supervisor
• Attendant
• Rescue
• Confined Space Tester and (or) Monitor
• Documentation of Training

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ENTRY

• The act by which a person intentionally passes
  through an opening into a confined space.
• Any part of the body passing through the opening
  is considered entry.

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ENTRANT

• The employee who will physically enter the
  confined space to perform the work.

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Entrants

• Entry supervisors will ensure that entrants
• are trained in
• Hazard Recognition
• Personal Protective Equipment (PPE)
• Self-Rescue
• Special Work Practices or Procedures

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Entrant Responsibilities

• To assure that the space has been adequately
  ventilated, isolated, emptied, or otherwise made
  safe for entry.
• To immediately exit a space, without question,
  upon word of the attendant, no matter what the
  reason.
• To follow all safety rules and procedures that
  apply to the job.
• To be familiar with the work to be performed and
  the procedures that apply to the job.
• To use the appropriate PPE whenever necessary.

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Entry Supervisor

• The employee responsible for coordinating the
  entry into the confined space. This must be a
  team leader or foreman.

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Evaluate the Space

• Determine that the space meets all the conditions
  set forth in the non-permit justifications
• Conduct atmospheric testing
• Evaluation must be certified by Entry
  Supervisors signature
• Determine that the confined space does not
• contain or have the potential to contain a
  hazardous atmosphere
• Continuous mechanical ventilation not acceptable
  as good atmosphere
• contain a material with the potential for
  engulfment
• Has an internal configuration which could trap or
  asphyxiate, or
• contain any recognized serious safety or health
  hazard

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Entry Supervisor

• Recognize the effects of exposure to hazards
  reasonably expected to be present
• Perform the duties and responsibilities in OSHA
  29 CFR 1910.146

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Supervisor Responsibilities

• To assure adequate protection is provided to the
  entrants by verifying adequate lockout/tagout and
  that all hazards are securely isolated.
• To support the attendants authority in
  controlling access to a confined space.
• To verify that all personnel have exited prior to
  closing the space.
• To assure that all personnel involved are aware
  of the hazards associated with the space.
• To assure that rescue services are available
  prior to entry.

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ATTENDANT

• The employee who remains outside the confined
  space and monitors the entrant(s) guards the
  space against unauthorized entry warns the
  entrants of any unusual conditions and summons
  the rescue personnel if needed.

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Attendant

• Entry supervisors will ensure the attendant is
  trained to perform the duties and
  responsibilities of 29 CFR 1910.146, and on the
  same requirements as those of an entrant or
  rescue personnel if the attendant is expected to
  perform those functions

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Attendant Responsibilities

• To monitor entrants during the job and during
  entry exit to help insure their safety.
• The attendant may not abandon his post for any
  reason while personnel are in the space unless
  relieved by another qualified attendant.
• To monitor atmospheric conditions in the space
  prior to and during entry.
• To control access to the confined space.
• To summon emergency assistance as needed.
• To assess hazards in and around the space, and
  take action on the same.
• To keep records of confined space work, such as
  air test results, personnel entry/exit, etc.

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Rescue

• All rescue team members shall receive hands-on
  practice in removing simulated victims from
  actual confined spaces annually
• Entry supervisors will ensure all rescue team
  members are trained. Note The Fire Chief is
  responsible for currency of FD primary
  secondary rescue team members
• Rescue duties and responsibilities
• Use of retrieval rescue equipment
• Proper wear and use of PPE
• CPR and basic first-aid

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CS Tester (or) Monitor

• Person designated to conduct tests of CS
  atmospheric conditions must be trained in the
  operation, calibration, and care of specific
  testing equipment to be used.
• Person conducting test must be fully trained and
  certified as qualified to interpret results
• The tester shall meet the training requirements
  of an entrant if entry is required to conduct the
  tests

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Documentation of Training

• All training for entry supervisors, entrants,
  attendants, testers and (or) monitors, rescue
  team members shall be certified, documented, and
  kept up-to-date.
• Certification shall contain each individuals
  name and dates of training/retraining, and
  initials or signature of trainer and (or)
  instructor
• Training shall be documented.
• Training records will be available for review by
  Safety and Fire Department

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SPECIFIC REQUIREMENTS (6)

• Entry Into Confined Spaces
• Testing Classification of CS
• Entry Into Immediately Dangerous to Life and
  Health (IDLH) Conditions
• Entry into Permit-Required Confined Spaces
• Entry into Non-Permit Confined Spaces
• Welding, Cutting, and Brazing Permit

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Entry Into Confined Spaces

• An entry permit must be applied for prior to
  entry into a permit-required CS. It certifies
  evaluation of all existing hazards and necessary
  protective measures have been taken. It is a
  checklist!
• Rescue procedures and equipment are of paramount
  importance
• Each completed entry permit to include those
  revoked or cancelled shall be retained for 1 year
  and available for review

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Contractor Confined Space Entry

• Contractors must be informed of the hazards
  within the space
• Contractors must follow their own established
  confined space entry procedure and use their own
  permit forms
• Contractors must supply their own attendants
• One attendant is acceptable for multiple
  companies entrants
• Contractors must supply their own air monitors
• Contractors must review entry after completion of
  job