Confined Spaces Program

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POLICY

[COMPANY NAME]’s policy is to ensure that employees are protected from the potential hazards involved with confined spaces (or permit spaces) at a worksite with one or more confined spaces. The company will comply with the OSHA permit-required confined space standard (29 CFR 1910.146).

For this program’s purposes, the following definitions apply:

Attendant – An individual stationed outside one or more confined/permit space(s) who assesses status of authorized entrants and must perform duties specified in 1910.146.

Authorized entrant – An employee authorized by entry supervisor to enter a permit space.

Competent person – One capable of identifying existing and predictable hazards in surroundings or working conditions related to entering and working in confined spaces, which are unsanitary, hazardous, or dangerous to employees, and has authorization to take prompt corrective measures to eliminate them.

Confined space – A space that:

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

Entry permit – Written or printed document provided by employer who designated space a permit space to allow and control entry. Contains information specified in 1910.146.

Entry supervisor – Qualified person (employer, foreman, or crew chief) responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, authorizing entry and overseeing entry operations, and terminating entry as required by this standard.

Hazard – A physical hazard or hazardous atmosphere.

Hazardous atmosphere – Atmosphere that may expose employees to risk of death, incapacitation, impairment of ability to self-rescue (escape unaided from a permit space), injury, or acute illness from one or more of the following causes:

• Flammable gas, vapor, or mist more than 10% of its lower flammable limit (LFL)
• Airborne combustible dust at a concentration that meets or exceeds its LFL
• Atmospheric oxygen concentration below 19.5 % or above 23.5 %
• Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in subpart D or subpart Z of 29 CFR 1926, which could result in employee exposure more than its dose or permissible exposure limit (PEL)
• Any other atmospheric condition that is immediately dangerous to life or health

Permit-required confined/permit space – Space that has one or more of the following characteristics:          

• Contains or has potential to contain a hazardous atmosphere
• Contains material that has potential for engulfing an entrant
• Has an internal configuration where an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section
• Contains any other recognized serious safety or health hazard

Physical hazard – Existing or potential hazard that can cause death or serious physical damage. Examples include, but are not limited to: explosives (as defined by paragraph [n] of 29 CFR 1910.146, definition of “explosive”); mechanical, electrical, hydraulic and pneumatic energy; radiation; temperature extremes; engulfment; noise; and inwardly converging surfaces. Physical hazards also include chemicals that can cause death or serious physical damage through skin or eye contact (rather than through inhalation).

Qualified person – One who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated their ability to solve or resolve problems relating to the subject matter, work, or project.

29 CFR 1926.1202 defines terms that could be applicable to this standard.

Employers should consult with affected employees and their authorized representatives on the development and implementation of all aspects of the permit space program. All information about permit-required confined spaces should be available for each affected employee and their authorized representatives at [LOCATION].

CONFINED SPACES IDENTIFICATION AND EVALUATION

Location examples where confined spaces may occur include, but are not limited to, the following; bins; boilers; pits (elevator, escalator, pump, valve, or other equipment); manholes (fuel, chemical, water, or other liquid, solid, or gas); incinerators; scrubbers; concrete pier columns; sewers; transformer vaults; heating, ventilation, and air-conditioning (HVAC) ducts; storm drains; water mains; precast concrete and other pre-formed manhole units; drilled shafts; enclosed beams; vessels; digesters; lift stations; cesspools; silos; air receivers; sludge gates; air preheaters; step-up transformers; turbines; chillers; bag houses; mixers/reactors; crawl spaces and attics.

An inspection of company premises/workplaces by a competent person has identified the following spaces as confined spaces and/or permit-required confined spaces:

Confined Spaces (List all spaces that meet the definition of a confined space. Include locations.)

Permit-Required Confined Spaces (List all spaces that also meet the definition of a permit-required confined space. Include locations.)

All permit-required confined spaces have been marked with warning signs reading: "Danger - permit-required confined space - authorized entrants only" or something similar. In addition, the employer must inform affected employees/contractors of the existence, location, and danger of each permit space in a timely manner and in a manner other than posting signs.

Rescue and Emergency Services

If the company uses outside services for rescues/emergencies, make sure to:

• Evaluate prospective rescuer’s ability to respond to a rescue summons in timely manner, considering the identified hazards
• Evaluate prospective rescuer’s proficiency with rescue-related tasks and equipment to function appropriately while rescuing entrants from permit spaces
• Select a rescue team or service from those evaluated that:
  • Has capability to reach a victim within an appropriate timeframe for the identified permit space hazards
  • Is equipped for, and proficient in, performing needed rescue services
  • Agrees to immediately notify employer if rescue services become unavailable

Once evaluated, the company should select rescue/emergency service and inform it about potential hazard(s) it may confront when called on to perform rescue on site. The company should provide rescue/emergency service access to all permit spaces where rescue may be necessary so it can develop appropriate rescue plans and practice rescue operations.

When the above situations occur, we will employ [RESCUE/EMERGENCY SERVICE] for rescues and emergencies. Contact [CONTACT NAME] at [PHONE #].

In some instances, the company may use a designated employee rescue team to provide rescue services. If company designates employees to provide permit space rescue, the following should apply:

• Provide affected employees with the personal protective equipment (PPE) needed to conduct permit space rescues safely and training so they are proficient in using PPE.
• Train affected employees to perform assigned rescue duties. Employer must ensure that such employees successfully complete the required training to establish proficiency as authorized entrants.
• Train affected employees in basic first aid and cardiopulmonary resuscitation (CPR). Employer should ensure at least one member of the rescue team or service holding a current certification in first aid and CPR is available.
• Ensure that affected employees practice making permit space rescues at least once every 12 months using simulated rescue operations (dummy, mannequin, or actual person removal from actual/representative permit spaces). Representative permit spaces should simulate the types of permit spaces where a rescue would be performed in opening size, configuration, and accessibility.

To facilitate non-entry rescue, retrieval systems or methods should be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. Retrieval systems should meet the following requirements:

1. Each authorized entrant should use a chest or full-body harness with a retrieval line attached at the center of the entrant's back near shoulder level, above the head or at another point that an employer can establish presents a profile small enough for successful removal. Wristlets may be used in lieu of a chest or full-body harness if an employer can demonstrate that their use is not feasible or creates a greater hazard and that using wristlets is the safest and most effective alternative.
2. The other end of the retrieval line should be attached to a mechanical device or fixed point outside the permit space so rescue can begin as soon as a rescue becomes necessary. A mechanical device should be available to retrieve personnel from vertical type permit spaces more than five feet (1.52 meters) deep.
3. Unsuitable retrieval equipment should not be used, including retrieval lines that have a reasonable probability of becoming entangled with the retrieval lines used by other authorized entrants, retrieval lines that will not work due to the internal configuration of the permit space, etc.

If an injured entrant is exposed to a substance for which a safety data sheet (SDS) or other similar written information is required to be kept at the worksite, that SDS or written information should be made available to the medical facility treating the exposed entrant.

DUTIES

Entry Supervisor

• Determines if conditions are acceptable for entry and terminates entry if conditions aren’t acceptable.
• Authorizes entry and oversees entry operations.
• Terminates entry procedures as required.
• Serves as an attendant if trained and equipped appropriately for that additional role.
• Verifies that appropriate entries have been made on the permit, all tests specified by the permit have been conducted, and all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin.
• Verifies a rescue team is available and instructed on rescue duties (an onsite team or a pre-arranged outside rescue service).
• Ensures rescue team members have current certifications in first aid and CPR.
• Removes any unauthorized individuals who may enter or attempt to enter the permit space during operation.
• Ensures transfer of responsibility as required by entry permit is done in manner that maintains acceptable entry conditions.

Attendant

• Knowledgeable of and able to recognize potential confined space hazards.
• Remains outside permit space during entry operations until relieved by another attendant.
• Maintains accurate count of all people in confined space and ensures all entrants are tracked in and out.
• Monitors surrounding activities to ensure personnel safety.
• Maintains effective and continuous communication with personnel during confined space entry, work, and exit.
• Orders personnel to evacuate confined space if they:
  • Observe a condition that is not allowed on the entry permit
  • Notice entrants acting strangely, possibly because of exposure to hazardous substances
  • Notice a situation outside the confined space that could endanger personnel
  • Notice a hazard within the confined space that has not been previously recognized or considered
  • Must leave their workstation
  • Must focus attention on the rescue of personnel in another confined space they are monitoring
• Immediately summons the rescue team/emergency service if rescue becomes necessary.
• Keeps unauthorized people out of the confined space, orders them out, or notifies authorized personnel of unauthorized entry.
• May act as attendant for more than one permit space if noted on the entry permit. 

Entrant

• Reads and observes entry permit requirements.
• Familiar with and understands potential hazards during entry, including information on the mode, signs or symptoms, and consequences of exposure.
• Remains alert to potential hazards while in confined space.
• Properly uses equipment required by the permit.
• Stays in contact with attendant.
• Immediately exits confined space when:
  • They are ordered to do so by an authorized/attendant person
  • They notice or recognize signs or symptoms of exposure
  • A prohibited condition exists
  • The evacuation alarm system sounds
  • The required task is completed.

Alert attendant(s) when:

• There is any warning sign or symptom of exposure to a dangerous situation
• The entrant detects a prohibited condition

TRAINING

The employer must provide training to each employee whose work is regulated by 29 CFR 1910.146 at no cost to the employee, and ensure that the employee possesses the understanding, knowledge, and skills necessary for the safe performance of the duties assigned under the standard. Training must result in an understanding of the hazards in the permit space and the method used to isolate, control, or protect employees from these hazards; for employees not authorized to perform entry rescues to be aware of the dangers of attempting such rescues; and that unauthorized employees are not to, under any circumstances, attempt such a rescue.

Training should be completed:

• Before an employee is first assigned duties
• Before there is a change in assigned duties
• Whenever there is a change in the permit space operations that presents a hazard that an employee hasn’t been trained about
• Whenever employer has reason to believe either that deviations have occurred from the permit space entry procedures or there are inadequacies in an employee’s knowledge or use of those procedures.

Employees should receive a written certification following training to document that they have been properly trained in their respective duties and the hazards and safety precautions involved in permit-space entry. The training should establish employee proficiency in the duties required in this program, and should introduce new or revised procedures, as necessary, for compliance with the confined space program.

Employers should maintain training records to show the required training has been completed. Training records should contain employee names, trainer names, and training dates. These documents should be available for inspection by employees and their authorized representatives while they are employed by [COMPANY NAME].

GENERAL TRAINING

All employees who will enter confined spaces should be trained in entry procedures. Personnel responsible for supervising, planning, entering, or participating in confined space entry and rescue should be adequately trained in their duties prior to any confined space entry. Training should include:

• Explanation of general hazards associated with confined spaces
• Discussion of specific confined space hazards associated with the facility, location, or operation.
• Reason for, proper use, and limitations of PPE and other safety equipment required for entry into confined spaces.
• Explanation of permits and other procedural requirements for conducting a confined space entry.
• A clear understanding of what conditions would prohibit entry.
• Procedures for responding to emergencies.
• Duties and responsibilities of the confined space entry team.
• Description of how to recognize symptoms of overexposure to probable air contaminants in themselves and coworkers, and methods for alerting an attendant.

Refresher training should be conducted as needed to maintain employee competence in entry procedures and precautions.

Employers who identify or receive notice of a permit space and have not authorized or trained employees, must take effective measures to prevent employees from entering a permit space in addition to complying with all other applicable requirements of this program.

SPECIFIC TRAINING

Atmospheric monitoring personnel training should include proper use of monitoring instruments, including instruction about:

• Proper equipment use
• Equipment calibration
• Sampling strategies and techniques
• Exposure limits (PELs, TLVs, LELs, UELs, etc.)

Attendant training should include:

• Procedures for summoning rescue or other emergency services
• Proper utilization of equipment used for communicating with entry and emergency/rescue personnel

Emergency response personnel training should include:

• Rescue plan and procedures developed for each type of confined space that is anticipated to be encountered
• Emergency rescue equipment use
• First aid and CPR techniques
• Work location and confined space configuration to minimize response time

VERIFICATION OF TRAINING

Periodic assessment of the effectiveness of employee training should be conducted by [Responsible Person]. Training sessions should be repeated as often as necessary to maintain an acceptable level of personnel competence.

When entry into a confined space is necessary, the entry supervisor may initiate entry procedures, including the completion of a confined space entry permit. Entry into a confined space should follow the standard entry procedure below.

PRIOR TO ENTRY

The entire confined space entry permit should be completed before a standard entry. Entry should be allowed only when all requirements of the permit are met, and it is reviewed and signed by an entry supervisor. The following conditions must be met prior to standard entry:

• Affected personnel are trained to establish proficiency in the duties that will be performed within the confined space.
• The internal atmosphere within the confined space is tested by the competent person with a calibrated, direct-reading instrument.
• Personnel is provided with necessary PPE as determined by the entry supervisor.
• Atmospheric monitoring happens during the entry. If a hazardous atmosphere is detected during entry:
  • Personnel within the confined space should be evacuated by attendant(s) or entry supervisor until space can be evaluated by competent person to determined how the hazardous atmosphere developed
  • Controls should be put in place to protect employees before reentry.

OPENING A CONFINED SPACE 

Any conditions making it unsafe to remove an entrance cover should be eliminated before cover is removed. When entrance covers are removed, the openings should be promptly guarded by a fall protection system that meets or exceeds 29 CFR 1926.502 (Fall Protection Systems Criteria and Practices) to prevent anyone from falling through. This barrier or cover should protect each employee from foreign objects entering the space. If the space is in a traffic area, adequate barriers should be erected.

ATMOSPHERIC TESTING

Atmospheric test data is required prior to entry into a confined space and is required to evaluate the permit space hazards and verify that acceptable conditions exist for entry into that space. If a person must go into the space to obtain needed data, then standard confined space entry procedures should be followed. Before entry into a confined space, the competent person should conduct testing for hazardous atmospheres. The internal atmosphere should be tested with a calibrated, direct-reading instrument for oxygen, flammable gases and vapors, and potential toxic air contaminants (in that order).

Testing equipment used in specialty areas should be listed or approved for use in such areas by the competent person. A nationally recognized laboratory, such as Underwriters Laboratories or Factory Mutual Systems, shall approve all testing equipment.

EVALUATION TESTING

The atmosphere of a confined space should be analyzed using equipment of sufficient sensitivity and specificity. The analysis should identify and evaluate any hazardous atmospheres that may exist or arise so appropriate permit entry procedures can be developed, and acceptable entry conditions stipulated for that space. Data and development evaluation and interpretation of the entry procedure should involve a technically qualified professional (consultant, certified industrial hygienist, registered safety engineer, certified safety professional).

VERIFICATION TESTING

A confined space that may contain hazardous atmosphere should be tested for residues of all identified or suspected contaminants. The evaluation testing should be conducted with specified equipment to determine that residual concentrations at the time of testing and entry are within acceptable limits. The tester should record results. The atmosphere should be periodically retested (frequency to be determined by the competent person) to verify that atmospheric conditions remain within acceptable entry parameters.

When there are changes in the use or configuration of a non-permit confined space that might increase the hazards to entrants, or some indication that the initial evaluation of the space may not have been adequate, each entry employer must have a competent person reevaluate that space.

ACCEPTABLE LIMITS

The atmosphere of the confined spaces should be within acceptable limits when the following conditions are maintained:

• Oxygen – 19.5% to 23.5%
• Flammable gas, vapor, or mist – less than 10% of the lower flammable limit (LFL)
• Toxicity – less than the dose or permissible exposure limit as published in 1926 subpart D or subpart Z, which could result in employee exposure more than its dose or permissible exposure limit (PEL)
  • Place other regulatory standards you would like to follow here (ACGIH, TLVs, etc.)
• Airborne combustible dusts – less than its lower flammability limit (LFL)
• Any other atmospheric condition that is immediately dangerous to life or health is controlled

ISOLATION AND LOCKOUT/TAGOUT SAFEGUARDS

All energy sources that are potentially hazardous to confined space entrants should be secured, relieved, disconnected, and/or restrained before employees are permitted to enter. Equipment systems or processes should be locked and/or tagged out as required by the [COMPANY NAME] lockout/tagout program, which complies with OSHA’s 29 CFR 1910.147 and American National Standards Institute (ANSI) Z244.1 (current edition), prior to permitting entry into the confined space. In confined spaces where complete isolation is not possible, the competent person shall evaluate the situation and make provisions for as rigorous an isolation as practical. Special precautions should be taken when entering double-walled, jacketed, or internally insulated confined spaces that may discharge hazardous material through the vessel’s internal wall.

Where there’s a need to test, position, or activate equipment by temporarily removing the lock or tag or both, a procedure should be developed and implemented to control hazards to the occupants. Any removal of locks, tags, or other protective measures should be done in accordance with the [COMPANY NAME] lockout/tagout program.

INGRESS/EGRESS SAFEGUARDS

Means for safe entry and exit should be provided for confined spaces. Each entry and exit point should be evaluated by the competent person to determine the most effective methods and equipment to enable employees to safely enter and exit a confined space.

Appropriate retrieval equipment or methods should be used whenever a person enters a confined space. Retrieval equipment use may be waived by the competent person if it increases the overall risks of entry or does not contribute to the rescue. A mechanical device should be available to retrieve personnel from vertical confined spaces greater than five feet deep.

ENTRY PERMITS

A confined space entry permit is the most essential tool for assuring safety during entry in confined spaces with known hazards, or with unknown or potentially hazardous atmospheres. The entry permit process guides the supervisor and workers through a systematic evaluation of the space to be entered. The permit should be used to establish appropriate conditions. Before each entry into a confined space, an entry permit needs to be completed by the [ENTRY SUPERVISOR]. The [ENTRY SUPERVISOR] should then communicate the contents of the permit to all employees involved in the operation and post the permit conspicuously near the work location. A standard entry permit should be used for all entries. (See confined space forms.)

Entry permits should be posted at the entrance of a confined space (see attached entry permit copy). Copies of all completed and/or canceled entry permits should be retained for one year after completing an entry.

SAFETY EQUIPMENT

The employer should provide the following equipment, as required and at no cost to each employee, properly maintain equipment, and ensure each employee uses equipment properly:

• Needed testing and monitoring equipment
• Needed ventilating equipment to obtain acceptable entry conditions
• Necessary communications equipment, including any electronic communication equipment for attendants assessing entrant status in multiple spaces
• PPE (engineering and work-practice controls do not adequately protect employees)
• Approved lighting equipment for ignitable or combustible properties of a specific gas, vapor, dust, or fiber that may be present and to enable employees to see well enough to work safely and to exit the space quickly in an emergency
• Barriers and shields
• Needed equipment for safe ingress and egress by authorized entrants (ladders, etc.)
• Rescue and emergency equipment not provided by rescue services
• Any other equipment necessary for safe entry into, exit out of, and rescue from, permit spaces

SUBCONTRACTORS, VENDORS, OTHERS

[COMPANY NAME] subcontractors, vendors, or outside employers should be required to submit written policies and procedures for entry into permit-required confined spaces that comply with 29 CFR 1910.146. Entry into confined spaces by these outside employers should be coordinated with and approved by the entry supervisor in charge of the permit space.

Subcontractors are responsible for providing training, equipment, testing, personnel, emergency services, and permits for entry into permit spaces by their employees. They should notify outside employers about confined space hazards, entry requirements, and hazards history in the permit spaces involved.

In cases where employees and subcontractors may enter the same permit spaces or where operations of outside employers may impact the hazards involved in the confined spaces, the entry supervisor should coordinate efforts and protective measures outside employers.

Before entry operations begin, the host employer should provide the following information to the controlling contractor (if applicable):

• The location of each known permit space
• The hazards or potential hazards in each space or the reason it is a permit space
• Any precautions that the host employer or any previous contractor or entry employer implemented for the protection of employees in the space

Location:			Space type:
Reason for entry:
Atmospheric hazards:		__ Oxygen deficiency  __ Combustible gas __ Toxic contaminants __ Chemical/Biological  __ Noise __ Other
Physical hazards:		__ Mechanical     __ Electrical     __ Heat __ PPE  __ Other
Hazard controls:		__ Ventilation   __ Lockout/tagout
Beginning date:	Beginning time:	Ending date:		Ending time:
	a.m.         p.m.			a.m. p.m.
Authorized personnel:
Entrant names with dept./shop/company:			Attendant names with dept./shop/company:
Required equipment:
Communication methods with entrants:  __Voice       __Radio       __Phone       __Visual       __Rope signals       __Other:   Communication methods to contact emergency services:  __Phone       __Radio     __Other:
PPE: __Coveralls       __Tyvek suit      __Leather gloves      __Chemical resistant gloves __Welding gloves       __Welding hood       __Eye protection       __Hearing protection   __Respiratory protection       __Safety shoes/boots       __Hard hat  __Harness/lifeline       __Tripod/winch       __Other:
Traffic control:  __Barricades       __Vests       __Flags __Signs			Hot works: __Yes (hot works permit required)      __No

 

Atmospheric Testing   Gas monitor type:                                                    Last calibration date:
		1st	2nd	3rd	4th	5th	6th	7th	8th
Tests:	Acceptable entry conditions
Oxygen:	19.5-23.5%
Combustible gas:	Below 10% LEL
Carbon monoxide:	0-25 ppm
	Tester initials:
Approvals
Entry supervisor____________________________     ________________________________                           (Print)                                                   (Sign)   I assumed responsibility of entry supervisor on _________(date) at ________(time).   Entry supervisor____________________________     ________________________________                           (Print)                                                   (Sign)   This confined space entry permit has been revoked because:     Entry supervisor____________________________     ________________________________                           (Print)                                                   (Sign)   Comments:

General Employee Training Acknowledgment