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    Confined Space Safety Policy

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    DOWNLOAD THE HYDROPOINT CONFINED SPACE ENTRY PERMIT HERE

    Purpose

    The purpose of this document is to outline the Confined Space Safety Policy for HydroPoint Data Systems; hereafter referred to as “The Company.” In an effort to prevent injury to personnel, this policy will ensure specific precautions are taken while working in and around confined spaces.

     

    Responsibilities

    The Company

    Shall provide training to all employees and personnel.

    • Maintain records of all training
    • Audit/inspect work conditions, operations, and documentation.
    • Provide each manager/supervisor with necessary training and assist each manager in identifying confined spaces encountered by the supervisor’s employees canceled permits to evaluate the overall effectiveness of the Confined Space Entry Program and ensure that employees participating in entry operations are protected from permit space hazards. 
    • Provide pedestrian, vehicle, or other barriers as necessary to protect entrants from external hazards; and
    • Verify that conditions in the permit space are acceptable for entry throughout the duration of an authorized entry.

    Safety Coordinator

    Supervisors, foreman and managers shall identify and report all job areas and locations that are or may be confined spaces.

    Controlling Contractor

    The ‘Controlling Contractor’ must provide the following information:

    • Location of each known permit space;
    • Hazards or potential hazards in each space;
    • Precautions that the Controlling Contractor or any previous controlling contractor or entry employer have implemented for the protection of employees in the permit space.

    A Competent Person

    Before work begins at a worksite, a Competent Person identifies all confined spaces in which one or more of the employees it directs may work and identifies each space that is a permit space.

     Attendant

    An individual stationed outside one or more permit spaces who monitors the authorized entrants and who performs all attendant's duties assigned. The attendant summons help in the event of an emergency and does not enter the permit space.

    Entrant

    An employee who is authorized by the company to enter a permit space. The entrant communicates with the attendant to check-in or request rescue. The entrant must obey all commands of the attendant to exit the space.

    Entry Supervisor

    The person (such as the foreman, or crew chief) responsible for determining 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.

    All affected company employees must understand the hazards prior to participating in entry into a permit required confined space.

    Policy

    The Company shall follow all OSHA requirements for practices and procedures to protect employees engaged in construction activities at a worksite with one or more confined spaces.

    Locations where confined spaces may occur include, but are not limited to, the following: Bins; boilers; pits (such as elevator, escalator, pump, valve or other equipment); manholes (such as sewer, storm drain, electrical, communication, or other utility); tanks (such as 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; and/or mixers/reactors. 29 CFR 1926.1201(a)

    Permit Required Confined Space

    The Company shall evaluate the workplace to determine if any spaces are permit-required confined spaces. If the workplace contains permit spaces, The Company shall inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces.

    The Company shall:

    • Implement the measures necessary to prevent unauthorized entry;
    • Identify and evaluate the hazards of permit spaces before employees enter them;
    • Develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including, but not limited to, the following:

    Provide the following equipment at no cost to employees, maintain that equipment properly, and ensure that employees use that equipment properly:

    • Testing and monitoring equipment 
    • Ventilating equipment needed to obtain acceptable entry conditions.
    • Communications equipment necessary for compliance with paragraphs 1910.146 (h)(3) and (i)(5).
    • Personal protective equipment insofar as feasible engineering and work practice controls do not adequately protect employees.
    • Lighting equipment needed to enable employees to see well enough to work safely and to exit the space quickly in an emergency.
    • Barriers and shields as required by paragraph 1910.146(d)(3)(v).
    • Equipment, such as ladders, needed for safe ingress and egress by authorized entrants.
    • Rescue and emergency equipment needed to comply with paragraph 1910.146 (d)(9), except to the extent that the equipment is provided by rescue services; and
    • Any other equipment necessary for safe entry into and rescue from permit spaces.               

    The employer shall publish a list of all confined spaces in the office. In addition to this, designated supervisors shall carry out the following tasks:

    • Classify confined spaces as "permit required," “Alternate Procedure” or "non-permit required.”
    • Identify personnel who will enter confined spaces.
    • Identify the personnel under their supervision required to wear respirators.
    • Instruct personnel on routine measurement of respiratory hazards in confined spaces.
    • Provide instruction/training on confined space hazards and entry procedures to applicable personnel.
    • Provide instruction/training to personnel on the proper use of equipment required for confined space entry.
    • Issuance and cancellation of entry permits.
    • Inspect and maintain all equipment used to enter confined spaces.
    • Maintain records of equipment maintenance and personnel training.
    • Inform personnel who may enter the permit confined space by posting warning/danger signs and by training.
    • Establish, and disseminate a lockout program for applicable workers.
    • Identify and evaluate the hazards of permit spaces prior to personnel entry.
    • Conduct pre-entry meetings to inform entrants of possible hazards that are likely to be encountered.
    • Conduct work site inspections to ensure compliance with confined space entry procedures.
    • Prevent entrance into prohibited permit spaces by taking necessary, and reasonable measures.

    Field Supervisor

    The field supervisor with confined space entry oversight responsibilities shall be trained in the significance of confined space entry procedures and shall be responsible for the implementation and enforcement of the elements of this procedure in the area of operation. Field supervisors are responsible for all elements listed in the definition for Entry Supervisor (see definition section).

    All spaces owned or operated by The Company that meet the definition of permit required confined spaces shall be identified and appropriately marked, and access to such spaces shall be controlled. Employees are prohibited from entering any space meeting the definition of permit required confined space, unless the following conditions are met:

    • The Company determines that employees must enter permit required confined spaces to perform the mission of the Unit and/or the duties of the employee.
    • Employees are trained in the duties under this policy which they are to perform.
    • The space is rendered safe for entry by:

    Permits issued under the procedures in this policy shall be limited in duration to no longer than eight hours. A formal review of the confined space procedure shall be performed by The Company during the annual inspection that covers site-specific situations, changes in working practice and also as part of an annual document review process, i.e., enhances existing content, removes system deficiencies.

    The company shall review entry operations when the measures taken under the permit space program may not protect employees and revise the program to correct deficiencies found to exist before subsequent entries are authorized.

    The company shall Review the permit space program, using the canceled permits retained under

    § 1926.1205(f), within 1 year after each entry and revise the program as necessary to ensure that employees participating in entry operations are protected from permit space hazards.

    The Company must consult with affected employees and their authorized representatives on the development and implementation of all aspects of the permit space program. The Company must make available to each affected employee and his/her authorized representatives all information required to be developed by this standard.

    Alternate Procedures to Enter a Space Under Non-Permit Conditions

    • All physical hazards in the space are eliminated or isolated through engineering controls so that the only hazard posed by the permit space is an actual or potential hazardous atmosphere.
    • Continuous forced air ventilation is utilized to maintain safe entry.

    Employee Controlled Confined Space

    Identification of Confined Spaces

    • The Company shall identify each space under their jurisdiction which meets the definition of confined space, if any exist, and shall maintain a list of such spaces.
    • The Company shall determine if the confined space meets the definition of permit required confined space.
    • Each confined space on the list shall be designated as a non-permit or permit space.
    • The hazards of each permit space shall be catalogued.

    Distribution

    The list shall be distributed to all affected managers and employees.

    Signage

    If the workplace contains permit spaces, the employer shall inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces. Signs shall meet the requirements of Danger signs.

    • The supervisor with jurisdiction over employees who are required to enter an identified confined space shall:
    • Receive training as an Entry Supervisor.
    • Determine whether employees enter permit spaces or perform work within non- permit spaces that may cause the space to meet the definition for permit required confined space during the work activities. If so, the supervisor shall:
    • The supervisor, with the assistance of The Company management as necessary, shall ensure that the rescue services are adequately trained and equipped to perform rescue operations from the space in compliance with safety regulations.
    • Rescue service must be on-site for immediately dangerous to life and health (IDLH) conditions while work is being performed. 1910.1461910.146
    • The supervisor shall procure this assurance in writing;

    For each entry into a non-permit space, the designated Entry Supervisor shall review the work to be performed, to determine and carry out the following:

    • If the work introduces a hazard into the space that will cause it to meet the definition for permit required confined space, the supervisor shall:
    • Upon termination of the permit, re-inspect the space and take whatever actions necessary to remove the created hazards; and
    • Reclassify the space as a non-permit space.

    If the work does not introduce a hazard, the Entry Supervisor may authorize entry into the space. For each entry into a permit space, the designated Entry Supervisor shall:

    • Perform the pre-entry duties of the Entry Supervisor on the permit space to be entered.
    • Prepare an entry permit, reclassify the space as a non-permit space, or authorize alternate entry procedures.
    • Perform the post-entry duties of the Entry Supervisor.
    • Collect the permit from the attendant at the end of entry, or prepare the documentation for reclassification or alternate entry; and
    • Maintain the permit or documentation for the required retention period.

    For the duration of each entry into a permit space, the entrants and attendants shall perform the duties outlined in these procedures and shall return the permit or documentation to the Entry Supervisor upon termination of entry. An attendant MUST be on duty outside the confined space for the duration of entry operations. If multiple spaces are to be assigned to a single attendant, include in the permit program the means and procedures to enable the attendant to respond to an emergency. 1926.1204(f)(g)

    A person MUST NOT ENTER a confined space at a work site without a valid entry permit. An employer must establish an entry permit system for a confined space that:

    • Lists the name of each worker who enters the confined space and the reason for their entry;
    • Gives the location of the confined space;
    • Specifies the time during which an entry permit is valid;
    • Considers the work being done in the confined space; and
    • Considers the code of practice requirements for entering, being in, and leaving a confined space.

    The Company will ensure that, before a worker enters a permit required confined space an entry permit is properly completed, signed by a competent person and a copy kept readily available.

    Contractors

    The Company shall ensure that every contract for work within an identified permit space, or work within a non-permit space that will introduce a reclassifying hazard, shall:

    • Apprise the contractor that the space is a permit-required confined space and of the hazards within the space.
    • Require the contractor to control entry into the space by a permit system meeting the requirements of 29 CFR 1910.146; and
    • Require the contractor to eliminate any temporary hazards created by the work or notify the supervisor responsible for the space of any permanent hazards created by the work.

    The Contractor or its designee shall notify the responsible supervisor prior to entry.

    • The supervisor shall notify any employees near or affected by entry; and
    • If employees shall enter the space with contracted employees, the supervisor shall ensure that entry operations are coordinated with the contractor or designee to assure that:

    The Contractor or designee shall meet with the supervisor after completion of the entry to provide notification of:

    • Any new permanent hazards created by the work; and/or
    • Any unidentified hazards encountered during the entry.

    Reevaluation

    The Company shall re-evaluate identified confined spaces within their jurisdiction to determine if such spaces should be added, deleted, or reclassified.

    • Re-Evaluation shall be performed:

    Reclassification

    A space classified by the employer as a permit-required confined space may be reclassified as a non-permit confined space under the following procedures:

    • 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, the permit space may be reclassified as a non-permit confined space for as long as the non-atmospheric hazards remain eliminated.
    • If testing and inspection during that entry demonstrate that the hazards within the permit space have been eliminated, the permit space may be reclassified as a non-permit confined space for as long as the hazards remain eliminated.
    • The employer shall document the basis for determining that all hazards in a permit space have been eliminated, through a certification that contains the date, the location of the space, and the signature of the person making the determination. The certification shall be made available to each employee entering the space or to that employee's authorized representative.
    • If hazards arise within a permit space that has been declassified to a non-permit space under paragraph 1910.146(c)(7), each employee in the space shall exit the space. The employer shall then reevaluate the space and determine whether it must be reclassified as a permit space, in accordance with other applicable provisions of this section.

    Field Staff

    Each manager shall determine by job title any field staff that may enter permit required confined spaces and shall document the determination. Managers of employees authorized to enter permit spaces shall:

    • Procure the equipment necessary for entry testing and develop procedures to provide Entry Supervisors with the equipment as necessary.
    • Designate and train Entry Supervisors, Attendant and Entrants.
    • Designate and train a Program Coordinator responsible for maintaining the required canceled permits and documentation.
    • Establish procedures to provide for rescue operations.
    • The manager may elect to develop procedures requiring Entry Supervisors to contact emergency services prior to each entry to procure coverage. Such procedures shall ensure that the Entry Supervisor determines that the contacted rescue services are properly trained and equipped to perform rescue in the specified space, are aware of the entry and exit times, agree to provide rescue coverage for that time, and will notify the attendant should rescue coverage end for any reason.
    • The manager may elect to establish other means of guaranteeing and certifying rescue coverage. Such procedures shall address training, practice, equipment, and other relevant issues.
    • Authorized employees encountering a permit space which they need to enter to carry out their job duties shall have a trained Entry Supervisor to coordinate with the entity controlling the space prior to entry.
    • The Entry Supervisor shall perform the pre-entry duties for the permit space in concert with the controlling entity.
    • If the controlling entity has a permit required confined space program:
    • If the controlling entity does not have a permit required confined space program or has not identified the space as permit required:
    • The Entry Supervisor shall prepare and issue the permit or prepare the required documentation for Alternate Entry Procedures or reclassification.
    • The Entrant and Attendant shall follow the procedures for their classification for the duration of the entry and return the permit or documentation to the Entry Supervisor at completion of the entry.
    • The Entry Supervisor shall perform post-entry duties in concert with the controlling entity.
    • If the controlling entity does not have a permit required confined space program, the Entry Supervisor shall oversee the return of the space to the condition prior to entry.
    • The Entry Supervisor shall immediately meet with the controlling entity to provide information on:

    The Entry Supervisor shall submit the canceled permit, and/or any documentation prepared as a result of entry to the Safety Coordinator, who shall retain the document for the required retention period. The Entry Supervisor shall also report any emergencies, evacuations, or other unexpected events related to the entry, which shall be recorded in writing by the Safety.

    Permits

    This program shall undergo an annual review, using the cancelled permits retained within 1 year after each entry shall be conducted by the HSE Officer to revise the program as necessary, and ensure that employees are protected. If no confined space entries were performed during a 12- month period, no review is necessary.

    The Company must consult with affected employees and their authorized representatives on the development and implementation of all aspects of the permit space program required and must make available to each affected employee and his/her authorized representatives all information required to be developed by this standard 1926.1212.

    Entry Permit

    Before entry is authorized, The Company shall prepare an entry permit. The Entry Supervisor identified on the permit shall sign it to authorize entry. The completed permit shall be made available at the time of entry to all authorized entrants or their authorized representatives. The duration of the permit may not exceed the time required to complete the assigned task or job identified on the permit.

    The entry permit that documents compliance and authorizes entry to a permit space shall identify:

    • The permit space to be entered;
    • The purpose of the entry;
    • The date and the authorized duration of the entry permit;
    • The authorized entrants within the permit space, by name or by such other means (for example, through the use of rosters or tracking systems) as will enable the attendant to determine quickly and accurately, for the duration of the permit, which authorized entrants are inside the permit space;

    This requirement may be met by inserting a reference on the entry permit as to the means used, such as a roster or tracking system, to keep track of the authorized entrants within the permit space.

    Content of the ‘Permit Required’ Entry Permit

    • Space to be entered.
    • Purpose of the entry.
    • Date and the authorized duration.
    • Names of authorized entrants.
    • Means of detecting an increase in atmospheric hazard levels in the event the ventilation system stops working.
    • Names of entry attendants.
    • Name & signature of Entry Supervisor.
    • Hazards of the permit space to be entered.
    • Measures used to isolate the permit space and to eliminate or control permit space hazards before entry.
    • Acceptable entry conditions.
    • Communication procedures used by authorized entrants and attendants to maintain contact during the entry.
    • Equipment, such as personal protective equipment, testing equipment, communications equipment, alarm systems, and rescue equipment, to be provided.
    • Any additional permits, such as for hot work, that have been issued to authorize work in the permit space.

    Written Permit Space Program

    If The Company decides that employees it directs will enter a permit space, The Company must have a written permit space program. The written program must be made available prior to and during entry operations for inspection by employees and their authorized representatives.

    Termination and Closing or Cancelling of Permits

    The Entry Supervisor shall terminate the confined space permit, at the end of the job operation, at the end of the shift or when the Entry Supervisor or Attendant determine that conditions in or near the confined space have changed and are potentially hazardous to the Entrants.

    The Entry Supervisor shall, at the conclusion of entry operation, close out the permit and provide the Safety Officer with the original copy of the Confined Space Permit.

    Emergency and Rescue Services

    Emergency and rescue services must be at each job site containing confined spaces for the immediately dangerous to life and health conditions. Emergency and rescue services shall be:

    • Provided by the Controlling Contractors facility.
    • Provided by an outside service who has examined the entry site, practice rescue and decline as appropriate, or
    • Provided by The Company by selecting a rescue team that is equipped and trained to perform necessary emergency and rescue services.

    The Company shall evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified. What will be considered timely will vary according to the specific hazards involved in each entry. For example, Respiratory Protection, requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres.

    Rescue Team

    The Company shall evaluate a prospective rescue service's ability, in terms of proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified.

    The Company shall select a rescue team or service from those evaluated that:

    • Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified.
    • Is equipped for and proficient in performing the needed rescue services.

    The Company shall inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site and provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations.

    Employees Designated for Rescue

    Personnel, equipment, and services necessary to perform an effective rescue shall be identified by The Company. They shall be identified in a way that uniquely marks them apart from regular personnel and equipment prior to entry into a permit required confined space.

    The Company shall also ensure the employees that have been designated to provide permit space rescue and emergency services shall take the following measures:

    • Provide affected employees with the personal protective equipment (PPE) needed to conduct permit space rescues safely and train affected employees, so they are proficient in the use of that PPE, at no cost to those employees.
    • Train affected employees to perform assigned rescue duties. The Company shall ensure that such employees successfully complete the training required to establish proficiency as an authorized entrant.
    • Train affected employees in basic first aid and cardiopulmonary resuscitation (CPR). The Company shall ensure that 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, by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces. Representative permit spaces shall, with respect to opening size, configuration, and accessibility, simulate the types of permit spaces from which rescue is to be performed.

    Non-Entry Rescue

    To facilitate non-entry rescue, retrieval systems or methods shall 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

    Each authorized entrant shall 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 entrant's head, or at another point which The Company can establish presents a profile small enough for the successful removal of the entrant. Wristlets may be used in lieu of the chest or full body harness if the use of a chest or full body harness is infeasible or creates a greater hazard and that the use of wristlets is the safest and most effective alternative.

    The other end of the retrieval line shall be attached to a mechanical device or fixed point outside the permit space in such a manner that rescue can begin as soon as the rescuer becomes aware that rescue is necessary. A mechanical device shall be available to retrieve personnel from vertical type permit spaces more than 5 feet (1.52 m) deep.

    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 shall be made available to the medical facility treating the exposed entrant.

    High Angle Rescue

    Because of the broad range of variables that exist in technical rescue, there is no hard and fast rule for conducting one. The format used for organizing a successful rescue is referred to as L.A.S.T. (Locate, Access, Stabilize, and Transport). The specific method for accomplishing any of these steps will differ with each rescue and should be selected based on experience and the multitude of factors unique to the current rescue scene.

    The list of guidelines and rules below are designed to minimize the danger to rescuers as they perform their duties. Because of the inherent risks involved in high angle rescue, the method of rescue offering the least risk to the rescuer will be used. The following methods are listed in increasing order of risk. Factors influencing the selection include patient condition, rigging time, available manpower and/or equipment, and terrain conditions.

    • Talk victim into self-rescue.
    • Walk or climb with a belay line.
    • Rappel or lower with a belay line.
    • Pick-off with an independent belay.

    Rescuer safety is paramount in any rescue situation. Prior to conducting any high angle operations, a Safety Officer and Rescue Group Supervisor will be clearly identified. The rescuer will establish a safe zone around the rigging and operations area as soon as possible.

    Additionally, all rescue personnel shall adhere to the following safety guidelines.

    • Helmets and rescue gloves shall be worn at all times.
    • Edge protection shall be used anywhere that a rope comes in contact with a hard surface.
    • All life safety ropes shall be double anchored prior to loading.
    • An independent belay shall be used. NFPA 1983 Standards on Life Safety Rope will be followed whenever possible.

    Anchors are a mixture of equipment, knot tying, and judgment. With this said, all lifelines shall have two independent anchors. A large heavy object may be used for both the primary and backup anchors. Anchors may be natural (trees and boulders), structural (buildings, bridges, and towers), vehicles, or picket pins.

    Knot Tying

    Knots shall be rated for strength by the percentage of rope strength that remain when the knot is tied; knots should always be tied off. 

    Rescue Equipment Inspection

    According to ANSI/ASSE Z359.2-2007 American National Standards Section 5.5.2. Fall protection and rescue equipment shall be inspected on a regular basis not to exceed one year (or more frequently if required by the manufacturer’s instructions) by a competent person or a competent rescuer, as appropriate, to verify that the equipment is safe for use.

    The inspection shall be documented and shall include (but is not limited to):

    • Absence or illegibility of markings or tags
    • Absence of any elements affecting the equipment form, fit or function
    • Evidence of defects in or damage to hardware elements including cracks, sharp edges, deformation, corrosion, chemical attack, excessive heating, alteration, or excessive wear
    • Evidence of defects in, or damage to, straps or ropes (fraying, unsplicing, enlaying, kinking, knotting, roping, broken or pulled stitches, soiling, abrasion, alteration, needed or excessive lubrication, excessive aging, or excessive wear)
    • Alteration, absence of parts, or evidence of defects in, damage to, or improper function of, mechanical devices and connectors
    • Any other condition that calls to question the suitability of the equipment for its intended purpose

    Rescue equipment shall be taken out of service when any inspection reveals that it may no longer serve the required function due to damage or wear, because the required inspection interval has been exceeded, because it does not meet the criteria of this standard.

    Pre-Permit Duties

    Pre-Permit Duties of the Entry Supervisor

    • The Entry Supervisor shall record on the permit a descriptive identification of the permit space and its location.
    • The Entry Supervisor shall record on the permit the date of entry, the time of issuance, and the time of expiration. No permit shall be issued for a period longer than eight hours.
    • The Entry Supervisor shall record on the permit the reason for the entry.
    • The Entry Supervisor shall survey the permit space without entry and review the work to be performed, to identify the existing or potential hazards. Such hazards shall be recorded on the permit.
    • The Entry Supervisor shall determine the actions necessary prior to entry to eliminate or control the hazards and shall record them on the permit.
    • If a potential or actual atmospheric hazard exists, testing shall be required.
    • The Entry Supervisor shall determine if the atmospheric hazard can be eliminated or controlled by purging, venting, inerting, continuous forced air ventilation, or combination.

    If the only hazard in a space is a hazardous atmosphere and Alternate Entry Procedures are the desired means of entry, forced air is required.

    • Engulfment Hazard elimination or control by blanking, binding, double block and bleed, line braking, or other methods.
    • Configuration Control means. Configuration hazards usually cannot be eliminated.
    • Other Serious Hazards elimination or control by lock-out/tag-out or other means.
    • The need for traffic control devices to isolate the permit space from vehicular and pedestrian traffic as well as any other potential external hazard.

    The Entry Supervisor shall determine and record the required equipment for entry.

    • Equipment for the Attendant to summon rescue and the Entry Supervisor is required for all permit entries.
    • Equipment designed to test oxygen, flammable gases, and carbon monoxide shall be required for all permit spaces with hazardous atmospheres.
    • Equipment designed to test levels of identified airborne contaminants shall be required where such have been identified.
    • A forced air ventilation system is required for Alternate Entry Procedures and shall be required if determined by the Entry Supervisor.
    • Personal protective equipment is required where hazards cannot be effectively eliminated or controlled.
    • Traffic control equipment is required if the permit space is not effectively isolated from vehicle or pedestrian traffic.
    • Mechanical rescue equipment is required unless its use creates a greater hazard or would not effectively contribute to rescue.
    • Body Harness with retrieval line attached at the upper back should be used whenever feasible.
    • Wristlets may be used where body harnesses are not feasible.
    • Mechanical retrieval devices shall be used for vertical entries into spaces deeper than five feet. Mechanical devices or fixed-point connection may be used otherwise.
    • Communication equipment is required where entrants will be out of voice range with the Attendant
    • Other equipment shall be selected as need requires.

    The Entry Supervisor shall identify the authorized entrants and at least one attendant and shall record their names on the permit. The Entry Supervisor shall determine the type of entry that is allowed.

    If the pre-entry survey proves that the only hazard existing in the space is atmospheric and continuous forced air ventilation is provided, the Entry Supervisor may authorize Alternate Entry Procedures under stipulation that:

    • The initial atmospheric tests indicate the atmosphere meets the entry requirements.
    • Forced Air Ventilation continues for the duration of the entry; and
    • The Attendant performs atmospheric tests once per hour and records them on the Air Monitoring Log on the permit.

    If the pre-entry survey proves that there are no atmospheric or configuration hazards in the permit space, and that all other identified hazards can be eliminated (as opposed to controlled) from outside the space prior to entry, the Entry Supervisor may reclassify the space as Non- Permit contingent upon the completion of all hazard elimination activities.

    • If a non-permit entry is approved, the employee designated as Attendant on the permit shall serve as Lead Entrant. The permit shall serve as the required documentation.
    • If no other type of entry is obtainable or selected, entry shall be by the permit process.
    • The Entry Supervisor shall indicate any other permits issued for simultaneous work within the space and shall indicate the means to contact rescue personnel.
    • The Entry Supervisor shall sign and issue the permit, effective upon the date issued and contingent upon completion of all pre-entry activities and expiring on the date indicated on the permit.

    Forced Air Ventilation

    Continuous forced air ventilation shall be used, as follows:

    • An employee may not enter the space until the forced air ventilation has eliminated any hazardous atmosphere.
    • The forced air ventilation shall be so directed as to ventilate the immediate areas where an employee is or will be present within the space and shall continue until all employees have left the space.
    • The air supply for the forced air ventilation shall be from a clean source and may not increase the hazards in the space

    The atmosphere within the space shall be periodically tested as necessary to ensure that the continuous forced air ventilation is preventing the accumulation of a hazardous atmosphere. Any employee who enters the space, or that employee's authorized representative, shall be provided with an opportunity to observe the periodic testing required by this paragraph. 1910.146(c)(5)(ii)(E)-(F)

    Air Monitoring

    Before an employee enters the space, the internal atmosphere shall be tested, with a calibrated direct-reading instrument, for oxygen content, for flammable gases and vapors, and for potential toxic air contaminants, in that order. Any employee who enters the space, or that employee's authorized representative, shall be provided an opportunity to observe the pre-entry testing required by this paragraph. The Company shall also reveal the atmospheric testing results to requested affected employees.

    The purpose of air monitoring is to identify and quantify airborne contaminants in order to determine the level of worker protection needed. Initial screening for identification is often qualitative, i.e., the contaminant, or the class to which it belongs, is demonstrated to be present but the determination of its concentration (quantification) must await subsequent testing. Two principal approaches are available for identifying and/or quantifying airborne contaminants:

    • The onsite use of direct-reading instruments.
    • Laboratory analysis of air samples obtained by gas sampling beg, filter, sorbent, or wet-contaminant collection methods.

    If a hazardous atmosphere is detected during entry:

    • Each employee shall leave the space immediately.
    • The space shall be evaluated to determine how the hazardous atmosphere developed; and
    •   Measures shall be implemented to protect employees from the hazardous atmosphere before any subsequent entry takes place.

    Portable Air Monitoring Equipment

    Portable air monitors are hand-held instruments that measure the concentration of combustible or toxic gases and vapors as well as oxygen concentration. All instruments used in USPL sound an audible alarm when concentrations exceed preset limits. Since air monitoring equipment is designed for various applications, each instrument may have its own operating characteristics and limitations.

    Specific initial and continuous monitoring requirements for Hot Work, Confined Space, and Excavations are specified in the respective policies. These policies should be referenced for air monitoring specifics.

    Pre-Entry Actions

    If the hazard assessment identifies a potential atmospheric hazard and a worker is required or authorized by an employer to enter the confined space, the employer must ensure that a competent worker performs a pre-entry atmospheric test of the confined space to:

    • Verify that the oxygen content is between 19.5 percent and 23.0 percent by volume,
    • Identify the amount of toxic, flammable, or explosive substance that may be present.
    • Any conditions making it unsafe to remove an entrance cover shall be eliminated before the cover is removed.
    • 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.

    The Company must ensure that as often as necessary after the first time a worker enters the confined space, a competent worker:

    • Performs atmospheric testing, and
    • Identifies and records any additional hazards.

    The Company must ensure that if there is a potential for the atmosphere to change unpredictably after a worker enters the confined space, the atmosphere is continuously monitored.

    If atmospheric testing identifies that a hazardous atmosphere exists or is likely to exist in a confined space, The Company must ensure that the confined space is ventilated, purged, or both before a worker enters the confined space.

    If ventilating or purging a confined space is impractical or ineffective in eliminating a hazardous atmosphere, the employer must ensure that a worker who enters the confined space uses personal protective equipment appropriate for the conditions within the confined space.

    The Entry Supervisor shall ensure that required equipment is procured and available, and that pre-entry actions are completed prior to entry. The Entry Supervisor may perform these duties or may delegate them to the Attendant and/or other authorized Entrants.

    Each pre-entry requirement successfully met shall be checked off in the block provided on the permit. When all requirements are completed, the responsible employee shall verify the actions by signing the permit.

    Required atmospheric testing shall be performed in the order indicated below after the pre-entry actions to address atmospheric hazards have been performed. Entry may proceed only if the tests indicate:

    • The percentage of oxygen in the permit space is between 19.5% and 23.5%.
    • The percentage of flammable gases is at or lower than 10 percent of the Lower Flammable Limit.
    • The parts per million parts (ppm) of carbon monoxide is at or lower than 17.
    • The amount of other identified air contaminants is/are less than one-half the PEL. Where more than one air contaminant is observed, those contaminants will be reviewed for additive effects.
    • The permit shall be posted at the point of entry into the space, and each authorized employee shall review it to become familiar with the hazards of the space and the acceptable entry conditions.

    The Company will ensure that workers within a confined space are protected against the release of hazardous substances or energy that could harm them.

    The Company shall also ensure that a worker does not enter a confined space unless adequate precautions are in place to protect a worker from drowning, engulfment, or entrapment.

    The Company will ensure that any hazardous energy in a restricted space is locked/tagged out.

    A person must not enter or work in a confined space if more than 20 percent of the lower explosive limit of a flammable or explosive substance is present in the atmosphere.

    Barriers and barricades will be set up and used to prevent unauthorized entry into the confined space.

    The Company shall implement pre-entry testing and periodic monitoring, provide an early warning system that continuously monitors for non-isolated engulfment hazards, and continuously monitor atmospheric hazards.

    The Company shall implement pre-entry testing and periodic monitoring, provide an early warning system that continuously monitors for non-isolated engulfment hazards, and continuously monitor atmospheric hazards 1926.1204(e).

    Entry

    Entrants shall:

    • Enter the space and perform the assigned work as expediently as possible
    • Wear and use all equipment required by the permit
    • Notify the Attendant or Lead Entrant periodically or upon request that all is well
    • Know all potential hazards that may be encountered during entry, including information on the signs, symptoms and consequences of the exposure
    • Use all required PPE such as eye protection, gloves and breathing equipment
    • Shall witness and verify calibrated air monitoring data and if approved, sign off, before entry is made
    • Is entitled to additional monitoring at any time
    • Always maintain communication with Attendant to ensure the Attendant is able to monitor the Entrants status and to identify the need for rescue
    • Immediately evacuate the space and alert the Attendant or Lead Entrant whenever any of the following occurs:

    Entry Supervisors shall:

    • Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure.
    • Verify, by checking that the appropriate entries have been made on the permit, that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin.
    • Terminate the entry and cancels the permit as required by paragraph (e)(5) of this section.
    • Verify that rescue services are available and that the means for summoning them are operable.
    • Remove unauthorized individuals who enter or who attempt to enter the permit space during entry operations; and
    • Determine, whenever responsibility for a permit space entry operation is transferred and at intervals dictated by the hazards and operations performed within the space, that entry operations remain consistent with terms of the entry permit and that acceptable entry conditions are maintained.

    Attendants

    For every confined space or restricted space entry, The Company shall designate a competent worker to be in communication with a worker in the confined space or restricted space. The Company will also ensure that the designated worker has a suitable system for summoning assistance.

    Duties of attendants. The employer shall ensure that each attendant:

    • Knows the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure. 
    • Is aware of possible behavioral effects of hazard exposure in authorized entrants.
    • Continuously maintains an accurate count of authorized entrants in the permit space and ensures that the means used to identify authorized entrants under paragraph (f)(4) of this section accurately identifies who is in the permit space.
    • Remains outside the permit space during entry operations until relieved by another attendant.
    • Communicates with authorized entrants as necessary to monitor entrant status and to alert entrants of the need to evacuate the space under paragraph (i)(6) of this section.
    • Monitors activities inside and outside the space to determine if it is safe for entrants to remain in the space and orders the authorized entrants to evacuate the permit space immediately under any of the following conditions.
    • Summon rescue and other emergency services as soon as the attendant determines that authorized entrants may need assistance to escape from permit space hazards.
    • Takes the following actions when unauthorized persons approach or enter a permit space while entry is underway.
    • Warn the unauthorized persons that they must stay away from the permit space.
    • Advise the unauthorized persons that they must exit immediately if they have entered the permit space; and
    • Inform the authorized entrants and the entry supervisor if unauthorized persons have entered the permit space.
    • Performs non-entry rescues as specified by the employer's rescue procedure; and
    • Performs no duties that might interfere with the attendant's primary duty to monitor and protect the authorized entrants.

    Monitor Inspection and Calibration

    All gas monitors shall be inspected and calibrated per manufacturer's recommendations and have a current calibration sticker on the monitor.

    Bump Tests

    Daily bump tests are performed to ensure the monitor and alarms are working correctly. Bump tests are required to be completed at the beginning of each day the monitor is in use per the requesting client and manufacturer's guidelines to ensure the monitor is functioning correctly

    Completion of Entry

    The Attendant or Lead Entrant shall assure that all entrants have exited the space. If the space was evacuated prior to completion of work:

    • The Attendant or Lead Entrant shall immediately terminate the permit by checking the appropriate box and describing the reasons for evacuation on the permit, then contacting the Entry Supervisor.
    • The Entry Supervisor shall:
    • If reentry must be performed:
    • If reentry is unnecessary:
    • If the entry was successfully completed, the Attendant or Lead Entrant shall:

    Training

    The Company must provide training to each employee whose work is regulated by this standard, 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 this standard. This training must result in an understanding of the hazards in the permit space and the methods used to isolate, control or in other ways protect employees from these hazards, and for those employees not authorized to perform entry rescues, in the dangers of attempting such rescues. OSHA 1926.1207(a). The Company shall ensure that at least one member of the rescue team or service holds a current certification in first aid and CPR. In addition, The Company shall ensure affected employees practice making permit space rescues at least once every 12 months by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces.

    Training required by this section must be provided to each affected employee in both a language and vocabulary that the employee can understand:

    • Before the employee is first assigned duties under this standard
    • Before there is a change in assigned duties
    • Whenever there is a change in permit space entry operations that presents a hazard about which an employee has not previously been trained
    • Whenever there is any evidence of a deviation from the permit space entry procedures required by § 1926.1204(c) or there are inadequacies in the employee's knowledge or use of these procedures.

    The training must establish employee proficiency in the duties required by this standard and must introduce new or revised procedures, as necessary, for compliance with this standard. 1926.1207(c)

    The employer must maintain training records to show that the training required has been accomplished. The training records must contain each employee's name, the name of the trainers, and the dates of training. The documentation must be available for inspection by employees and their authorized representatives, for the period of time the employee is employed by that employer.

     The documentation must be available for inspection by employees and their authorized representatives, for the period of time the employee is employed by that employer.

    The Company shall ensure that a worker assigned duties related to confined space or restricted space entry is trained by a competent person in:

    • Recognizing hazards associated with working in confined spaces or restricted spaces
    • Performing the worker’s duties in a safe and healthy manner

    The Company will ensure that competence in the following is represented in the workers responding to a confined space or restricted space emergency.

    • First aid
    • The use of appropriate emergency response equipment
    • Procedures appropriate to the confined space or restricted space Training may be performed in-house or by a 3rd party.

    Training for all Employees

    The supervisor shall ensure that each employee receives awareness training on:

    • The identifying characteristics of a confined space.
    • The identifying characteristics of a permit space.
    • The authorization or prohibition of their job classification to enter permit spaces.
    • Required actions when working around or near a permit space entry.
    • The authority of authorized Attendants and Entry Supervisors.

    Each affected employee shall be trained prior to initial assignment, prior to a change in assigned duties, if a new hazard has been created or special deviations have occurred.

    Training shall be required:

    • During orientation
    • Within two months of the determination of the employee's entry authorization, but prior to entry
    • Whenever the supervisor becomes aware that the employee has failed to follow the instructions provided in the training

    The Supervisor shall provide the Program Coordinator with notification that training has been received.

    Entry Operations

    The Company shall develop and implement procedures (such as closing off a permit space and canceling the permit) necessary for concluding the entry after entry operations have been completed.

    The Company shall review entry operations when there is reason to believe that the measures taken under the permit space program may not protect employees and revise the program to correct deficiencies found to exist before subsequent entries are authorized.

    Examples of circumstances requiring the review of the permit space program are:

    • Any unauthorized entry of a permit space
    • The detection of a permit space hazard not covered by the permit.
    • The detection of a condition prohibited by the permit.
    • The occurrence of an injury or near-miss during entry.
    • A change in the use or configuration of a permit space, and employee complaints about the effectiveness of the program.

    Multiple Entrants

    When The Company arranges to have employees of another employer perform work that involves permit space entry or confined space entries, The Company shall:

    • Inform the contractor that the workplace contains permit spaces and that permit space entry is allowed only through compliance with a permit.
    • Apprise the contractor of the elements, including the hazards identified and The Company’s experience with the space, that make the space in question a permit space.
    • Apprise the contractor of any precautions or procedures that The Company has implemented for the protection of employees in or near permit spaces where contractor personnel will be working.
    • Coordinate entry operations with the contractor, when both The Company personnel and contractor personnel will be working in or near permit spaces.
    • Debrief the contractor at the conclusion of the entry operations regarding the permit spaced program followed and regarding any hazards confronted or created in permit spaces during entry operations.

    Program Coordinators

    The Company shall ensure that the designated Program Coordinator receives training in:

    • The requirements of this policy and procedures
    • The duties the Coordinator shall perform.

    Training shall be provided:

    • Within two months after designation as Program Coordinator
    • Within one month of revisions to this policy and/or procedures

    Entry Supervisors, Attendants, and Entrants

    The Supervisor shall ensure that employees designated as Entry Supervisors, Attendants, and/or Entrants receive training in:

    • The requirements of this policy and any Procedures
    • The duties, authority, and responsibilities of Entry Supervisors, Attendants, Lead Entrants, and Entrants
    • The types of hazards expected to be encountered in permit spaces.
    • The calibration, use, care and cleaning of equipment expected to be used during entry operations.
    • The performance of pre-entry actions expected to be required in permit spaces.

    Training shall be provided:

    • Prior to assignment or authorization of duties within permit spaces
    • Within one month after revisions of this policy or procedures -Assignment or authorization for permit space entry shall be suspended until training is completed.
    • Whenever the supervisor becomes aware that an employee is deviating from the procedures of this policy. Assignment or authorization for permit space entry shall be suspended until training is completed; and annually.

    The supervisor shall develop written certification that each affected employee has successfully completed training.

    Certification shall include:

    • Employee Name
    • Authorized Duty (Entry Supervisor, Attendant, and/or Entrant)
    • Name & signature of the Trainer
    • Synopsis of topics covered
    • Date of training

    A copy of the certification shall be provided to the employee and the employer authorized representative.

    Multi-Employer Procedure

    When the Company arranges to have employees of another employer perform work that involves permit space entry The Company shall:

    • Inform the contractor that the workplace contains permit spaces and that permit space entry is allowed only through compliance with a permit space program meeting the requirements of this section.
    • Appraise the contractor of the elements, including the hazards identified and the Controlling Contractor’s experience with the space, that make the space in question a permit space.
    • Appraise the contractor of any precautions or procedures that The Company has implemented for the protection of employees in or near permit spaces where contractor personnel will be working.
    • Coordinate entry operations with the contractor, when both The Company personnel and contractor personnel will be working in or near permit spaces.

    In addition to complying with the permit space requirements that apply to all employers, each contractor who is retained to perform permit space entry operations shall:

    • Obtain any available information regarding permit space hazards and entry operations from the host employer.
    • Coordinate entry operations with the host employer, when both host employer personnel and contractor personnel will be working in or near permit spaces, as required by paragraph (d)(11) of this section; and
    • Inform the host employer of the permit space program that the contractor will follow and of any hazards confronted or created in permit spaces, either through a debriefing or during the entry operation.

    Personal Protective Equipment (PPE)

    The Company will ensure that the personal protective equipment and emergency equipment is available to workers undertaking rescue operations in a confined space to perform a timely rescue and will ensure that a worker does not enter or remain in a confined space unless an effective rescue can be carried out.

    The Company will ensure that the emergency response plan includes the emergency procedures to be followed if there is an accident or other emergency, including procedures in place to evacuate the confined space immediately.

    Definitions

    Confined Space - A space 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.

    Entrant Attendant - An individual stationed outside one or more permit spaces who monitors the authorized entrants and who performs all attendant's duties assigned in the employer's permit space program.

    Rescue - To free from danger, harm or confinement. Confined space rescue can be a very dangerous act. Statistics show that more than 60 percent of those who die in confined spaces are people attempting to perform a rescue.

    Confined Space Rescues are technically challenging because of the environment in which they occur. The spaces, such as underground vaults, silos, storage tanks, and sewers, are often narrow and constricting, preventing easy access by rescuers.

    Spotter - An employee trained to look. The purpose of a spotter is to assist the operator in maneuvering equipment into position to prevent injury to the operator, spotter or other personnel or prevent property damage.