CONFINED SPACE ENTRY PROGRAM

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1 A P P E N D I X 11 CONFINED SPACE ENTRY PROGRAM AP11.1. Purpose. AP11.2. Policy. To establish CBP policy for addressing the identification and protocol for safe entry and working in confined spaces. This policy addresses initial identification and risk assessment of confined spaces, entry procedure development and approval, and emergency rescue procedures. CBP employees will not enter any confined space without first assessing the potential dangers that may be present. CBP employees shall not enter any permit-required confined space unless acceptable entry conditions exist and all the requirements of the OSHA Permit Required Confined Space Entry Standard (29 CFR ) have been met. AP11.3. Background. Work in confined spaces presents unusual and potentially severe hazards to employees who conduct examinations of truck and railroad tankers, ship cargo holds, and paint lockers that meet certain requirements. As a matter or routine, CBP does not consider all truck trailers and sea containers as confined spaces. Each situation must be assessed on a case by case basis. Confined spaces may contain unsafe atmospheric conditions, engulfment hazards, and physical hazards that can quickly become lethal. Entry into a confined space must always be considered potentially dangerous to life and health. AP11.4. Definitions. Attendant means a trained individual stationed outside one or more permit spaces who monitors the authorized entrants and who performs all attendantʼs duties assigned in the permit space program. An attendant is required for all permit-required confined space entries. Authorized entrant means an employee who is authorized and trained to enter a permit space. Confined space is any area that has the following characteristics: A. Is large enough and so configured that an employee can bodily enter and perform assigned work. B. Has limited or restricted means for entry and exit. C. Is not designed for continuous human occupancy. 125

2 Confined spaces may include, but are not limited to, storage tanks, tanker trucks and railroad cars, process vessels, pits, vats, vaults, sewers, tunnels, manholes, cells, heating/air conditioning ducts, ship holds, wells, and commercial aircraft fuel tanks. Certified Industrial Hygienist means an industrial hygienist who has attained, through education and testing, certification by the American Board of Industrial Hygiene. Emergency means any occurrence (including any failure of hazard control or monitoring equipment) or event internal or external to the permit space that could endanger entrants. Engulfment means the surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction or crushing. Entry means the action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrantʼs body breaks the plane of an opening into the space. Entry permit (permit) is a document that is signed by the entry supervisor indicating that safety guidelines and applicable monitoring procedures have been and are achieved prior to permit-required confined space work. CF-515 is the CBP Confined Space Entry Permit. Entry supervisor means the person (such as the Chief Inspector or Supervisory Inspector) trained and 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 by this policy. (Note: An entry supervisor also may serve as an attendant or as an authorized entrant, as long as that person is trained and equipped as required by 29 CFR for each role he or she fills.) Hazardous atmosphere means an atmosphere that may expose employees to the risk of death, incapacitation, impairment or ability to self-rescue (that is, escape unaided from a permit space) injury, or acute illness from one or more of the following causes: A. Flammable gas, vapor, or mist in excess of 10 percent of its lower explosive limit (LEL); B. Airborne combustible dust at a concentration that meets or exceeds its LEL; (Note: This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet or less) C. Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent; D. Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in 29 CFR 1910 Subpart G, Occupational Health and Environmental Control, or in Subpart Z, Toxic 126

3 and Hazardous Substances, and which could result in employee exposure in excess of its dose or permissible exposure limit; (Note: An atmospheric concentration of any substance that is not capable of causing death, incapacitation, impairment or ability to self-rescue, injury or acute illness due to its health effects, is not covered by this provision.) E. Any other atmospheric condition that is immediately dangerous to life or health. (Note: For air contaminants for which OSHA has not determined a dose or permissible exposure limit, other sources of information, such as Material Safety Data Sheets that comply with the Hazard Communication Standard, 29 CFR , or other published information and internal documents, can provide guidance in establishing acceptable atmospheric conditions) Hot work means work that produces arc, sparks, flames, heat, or other sources of ignition. This includes drilling, welding, cutting, grinding, burning and heating. Immediately dangerous to life or health (IDLH) means any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individualʼs ability to escape unaided from a permit space. (Note: Some materials - hydrogen fluoride gas and cadmium vapor, for example - may produce immediate transient effects that, even if severe, may pass without medical attention, but are followed by sudden, possibly fatal collapse hours after exposure. The victim feels normal from recovery from transient effects until collapse. Such materials in hazardous quantities are considered to be immediately dangerous to life or health.) Isolation means the process by which a permit space is removed from service and completely protected against the release of energy and material into the space. Examples of such action includes: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; blocking or disconnecting all mechanical linkages; etc. Lockout/Tagout: Lockout means the placement of a lockout device on an energy isolating device, in accordance with established procedure, ensuring that the energy isolating device and the equipment being controlled cannot be operated until the lockout device is removed. Tagout means the placement of a tagout device on an energy isolating device, in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed. Marine Chemist means an individual who possesses a current Marine Chemist Certificate issued by the National Fire Protection Association. Non-permit confined space means a confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm. 127

4 AP11.5. Hazards. Oxygen-deficient atmosphere means an atmosphere containing less than 19.5 percent oxygen by volume. Oxygen enriched atmosphere means an atmosphere containing more than 23.5 percent oxygen by volume. Permit-required confined space (permit space) means a confined space that has one or more of the following characteristics: A. Contains or has a potential to contain a hazardous atmosphere; B. Contains a material that has the potential for engulfing an entrant; C. Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or D. Contains any other recognized serious safety or health hazard. Permit required confined space program (permit space) means the local CBP officeʼs overall written program for controlling and, where appropriate, for protecting employees from permit space hazards and for regulating employee entry into permit spaces. Permit system means the local CBP officeʼs written procedure for preparing and issuing permits for entry and for returning the permit space to service following termination of entry. Prohibited condition means any condition in a permit space that is not allowed by the permit during the period when entry is authorized. Rescue service means the personnel designated to rescue employees from permit spaces. Retrieval system means the equipment (including a retrieval line, chest or fullbody harness, wristlets, if appropriate, and a lifting device or anchor) used for non-entry rescue of persons from permit spaces. Testing means the process by which the hazards that may confront entrants of a permit space are identified and evaluated. Testing includes specifying the tests that are to be performed in the permit space. (Note: Testing enables employers both to devise and implement adequate control measures for the protection of authorized entrants and to determine if acceptable entry conditions are present immediately prior to and during entry.) The primary hazards associated with confined spaces are: A. Lack of oxygen. Insufficient oxygen in the air may result from displacement by other gases, rusting, or organic matter and bacteria using up the available oxygen. B. Toxic and suffocating gases. Some typical gases encountered are hydrogen sulfide, carbon monoxide, carbon dioxide and fumes from welding. Also, gases or vapors present from the material currently being stored or residual from material previously stored in the space. 128

5 C. Combustible gases/vapors. Fire or explosion may result from use of solvents/cleaners in the area, infiltration of combustible gases, or decomposition of organic matter resulting in generation of combustible gas. D. Engulfment. Individual(s) can become surrounded and captured by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction or crushing. E. Physical hazards. Mechanical crushing hazards or sudden releases of energy that can incapacitate or cause death. It is extremely important to note that the lack of oxygen or the presence of dangerous gases and vapors often is not immediately apparent to the senses. Therefore, the hazards must always be assumed to be present. Other hazards sometimes associated with confined spaces are temperature extremes, noise, chemical and mechanical hazards, and falls. AP11.6. Responsibilities. AP Principal Field Officers (PFOs) are defined as: Director, Field Operations (DFO), Port Directors, Laboratory Directors, and Chief Patrol Agents. PFOs shall: A. Assess and review all potential confined spaces that employees may enter during the course of their duties. Based upon this review, make a written determination whether the spaces identified meet confined space or permit required confined space criteria. If employees will not be allowed to enter permit-required confined spaces this should be communicated to all employees in writing at least annually. B. If a determination is made that employees may encounter and enter permit-required confined spaces in the course of their job, including mobile and variable site permit-required confined spaces, appoint a sufficient number of entry supervisors. C. Develop appropriate standard operating procedures (SOPs) and establish an entry permit program to ensure entrants are protected from confined space hazards. Submit the SOPs and entry-permit program to the Human Resources Management, Safety and Occupational Health Branch for approval prior to being implemented. D. Ensure that all employees who work in or around confined spaces, or are involved in the confined space entry process, are adequately trained prior to being assigned duties in or around confined spaces. E. Provide the necessary personal protective, safety, and test equipment. 129

6 AP AP F. Ensure that this program and the National Policy for Safe Entry into Confined Spaces are fully implemented and enforced. G. Ensure that all records required by Section 11.9 of this policy are properly maintained. H. Conduct an annual review of the permit-required confined space written program, including a review of all cancelled permits of the previous year, and modify the program as required. Safety and Occupational Health Branch shall: A. Set minimum standards for program development and assist the PFOs in developing site-specific confined space entry programs. B. Review and approve all written confined space programs prior to implementation. C. Assist field offices in the selection of personal protective, safety, and test equipment. D. Approve the course curriculum and instructor qualifications for the confined space entry training course(s) sponsored by the CBP Academy and the Office of Training and Development. Entry Supervisors will: A. Know the hazards that may be encountered during entry, including information on the mode, signs or symptoms, and consequences of exposure to the hazards. B. Determine that the necessary procedures, practices, and equipment for safe entry are present before allowing entry, including work site control to prevent unauthorized entries. C. Terminate entry when unacceptable conditions exist. D. Determine at appropriate intervals that entry operations remain consistent with the terms of the permit, and that acceptable entry conditions are present. E. Ensure that the communication equipment used to summon either the in-house rescue team or other emergency assistance is operating correctly. F. Take necessary measures for concluding an entry operation, such as closing off a permit space and canceling the permit, once the work authorized by the permit is completed. G. Ensure that any non-cbp officials working with CBP in confined spaces (i.e., State and local officers, National Guard or contractors), are aware of the hazards of the space and the need to follow appropriate entry procedures. 130

7 AP AP Authorized Entrants will: A. Know the hazards that may be faced during entry, including information on the mode, signs and symptoms, and consequences of exposure to hazards. B. Communicate with the attendant as necessary to enable the attendant to monitor entrant status and to enable the attendant to alert entrants of the need to evacuate the space when required. C. Properly use equipment needed for safe entry and exit, and ensure that the necessary PPE and equipment has been provided. D. Alert the attendant whenever there is recognition of any sign or symptom of exposure to a dangerous situation, or a prohibited condition is detected. E. Exit the confined space when the attendant orders evacuation, when an alarm is activated, when the entrant perceives they are in danger. Attendant (Standby Person): A. Know the hazards that may be present during entry including information on the mode, signs and symptoms, and consequences of the exposure. B. Maintain an accurate count and identification of entrants in the space. C. Remain outside the occupied space until relieved by another attendant. D. Maintain effective and continuous contact with entrants during entry. E. Monitor activities inside and outside the space to determine if it is safe for entrants to remain. F. Order entrants to evacuate when a condition exists that could endanger the entrants. G. Summon rescue and other emergency services when necessary. H. Prohibit entry of unauthorized persons. I. Perform non-entry rescues. Attendants will not enter the permit space to attempt rescue of entrants. AP11.7. Procedures. AP Confined Space Identification: Each CBP workplace shall review and assess the spaces that employees may enter during the course of their duties. Based upon this review, determine whether the spaces meet the criteria 131

8 AP AP as a confined space. If the space meets the criteria as a permitrequired confined space, all OSHA requirements contained in 29 CFR must be put into place and training provided prior to entry. CBP controlled spaces identified as permit-required confined spaces shall be properly labeled. Written Program CBP offices that allow employees to enter confined spaces must develop standard operating procedures (SOP) for confined space entry. CBP offices that allow employees to enter permit-required confined spaces must develop a site- specific written permit program that addresses responsibilities and procedures for safe entry. The written permit program must include procedures to: A. Determine the permit-required confined spaces and identify them for workers to prevent unauthorized entry; B Determine the actual and potential hazards associated with the space at the time of entry; C. Assure that control measures used in the confined space are effective. This is achieved by appropriate testing; D. Provide appropriate barriers or other means to protect the workers entering the confined space and the attendant(s), and to protect non-entering workers from hazards arising from the confined space; E. Identify by job titles those persons who must sign the entry permit and the duties of each, including the person in charge of the entry; F. Provide for pre-planned emergency rescue procedures; G. Provide an attendant for each entry, where applicable, and specify the duties of that attendant; H. Assure proper calibration of test and/or monitoring equipment; I. Assure that workers who participate in entry of a permit entry confined space in any capacity have been properly trained; J. Develop and implement a system for preparation, issuance, use, and cancellation, and annual review of entry permits. CF-515 is the CBP Confined Space Entry Permit; K. Develop and implement procedures necessary for concluding the entry after entry operations have been concluded. Employee Training A. Initial training shall be provided for employees before permitrequired confined space entry may take place. The training must encompass general confined space safety, the site specific 132

9 AP AP AP confined space program, responsibilities of the entrant, attendant, and entry supervisors, OSHA Standard 29 CFR , use of test equipment to determine atmospheric hazards, and the use and maintenance of applicable safety and personal protective equipment. B. If in-house rescue teams are used, the teams will be trained in all aspects of confined space rescue, basic first aid, and cardiopulmonary resuscitation (CPR). At least one member of the in-house team must have current certification in first aid and CPR. In-house rescue team members will conduct a practice rescue at least once a year in a representative type of confined space. C. Training will be repeated whenever there are changes in the space or procedures that present a hazard the employees training did not cover or when an evaluation determines inadequacies in the employeeʼs knowledge. Retrieval systems and methods for non-entry rescue will be used in permit-required confined space entries except where obstructions or turns would prevent line retrieval or increase the overall risk of entry. A mechanical retrieval device shall be available to retrieve personnel from vertical type permit spaces with a drop of greater than 5 feet. Equipment Appropriate equipment shall be provided to safely enter and exit confined spaces. All equipment shall be maintained in accordance with the manufacturerʼs recommendations. Equipment includes: A. Testing and monitoring equipment; B. Forced-air ventilating equipment; C. Communications equipment; D. Personal Protective Equipment (as needed when feasible engineering or work practice controls do not adequately protect employees); E. Lighting equipment; F. Barriers and shields; G. Equipment for safe ingress and egress (e.g. ladders); H. Rescue and emergency equipment. I. Any other equipment needed for safety entry into and rescue from permit spaces. Atmospheric Testing Testing must be done prior to entry and periodically during entry operations, as necessary. Testing sequence will be oxygen 133

10 AP AP level, flammable atmosphere, and then for any appropriate toxic atmosphere that may be in the space, in that order. Test equipment will be properly maintained and calibrated in accordance with the manufacturerʼs recommendations. Ventilation Forced-air ventilation and isolation techniques will be used to minimize or eliminate potential hazards. Where the existence of dangerous air contamination, oxygen deficiency, or oxygen enrichment is demonstrated by testing, any existing ventilation shall be augmented by appropriate means if practical and feasible. When additional forced-air ventilation has removed dangerous air contamination, oxygen deficiency, or oxygen enrichment as demonstrated by additional testing conducted and recorded on the permit, entry into and work within the space may proceed. CBP officers will not enter permitrequired confined spaces while hazards are present. Alternative Procedures The OSHA standard allows the use of alternate procedures, which exempts many of the strict compliance OSHA requirements for confined space entry (with the exception of training), under the following conditions: A. The only hazard posed is an actual or potential hazardous atmosphere; B. It has been demonstrated that continuous forced-air ventilation alone is sufficient to maintain safety for entry; C. Monitoring and inspection data has been developed that supports only an atmospheric hazard and continuous forced air ventilation alone maintains safety; D. If an initial entry is necessary to test or evaluate the space, an entry permit is used. E. Entry into the space complies with the following: 1) Any condition(s) making it unsafe to remove an entrance cover are eliminated before the cover is removed. 2) When entrance covers are removed, the openings are promptly guarded by a railing, temporary cover, or other temporary barrier that will prevent an accidental fall through the opening and that protects each employee working in the space from foreign objects entering the space. 134

11 3) Before an employee enters the space, the internal atmosphere is tested, with a calibrated direct-reading instrument, for the following conditions in the order listed: (a) Oxygen content; (b) Flammable gases and vapors; and (c) Potential toxic air contaminants. 4) There is no hazardous atmosphere within the space whenever any employee is inside the space. 5) Continuous forced air ventilation is used as follows: (a) No employee enters the space until the forced air ventilation has eliminated any hazardous atmosphere; (b) The forced air ventilation is directed so as to ventilate the immediate areas where an employee is or will be present within the space and continues until all employees leave the space; (c) The air supply for forced air ventilation must be from a clean source and must not increase the hazards in the space. 6) The atmosphere within the space is periodically tested as necessary to ensure that the continuous forced air ventilation is preventing the accumulation of a hazardous atmosphere. 7) If a hazardous atmosphere is detected during entry: (a) Each employee leaves the space immediately; (b) The space is evaluated to determine how the hazardous atmosphere developed; and (c) Measures are implemented to protect employees from the hazardous atmospheres before any subsequent entry. 8) The space is verified for safe entry and that the necessary protective measures described above have been taken through a written certification. The written certification for use of alternate procedures must be made available to each employee entering the space. CF-557 is the CBP Alternate Entry Certification form. 135

12 AP AP AP Rescue Services Arrangements must be made for rescue services before entry is to proceed. In most cases, CBP offices will use off-site rescue services. Off-site rescue services must be evaluated to ensure they are trained, equipped, and capable of timely performing rescue. The procedures to evaluate the capabilities of an off-site rescue team are provided in the OSHA standard (29 CFR , Appendix F). If on-site rescue is to be used, the rescue team must be trained and equipped in accordance with 29 CFR and this policy (see Section ). Retrieval systems and methods for non-entry rescue will be used for all entries into permit spaces, except in situations where obstructions or turns would prevent line retrieval or increase the overall risk of entry. A mechanical retrieval device will be made available for entries into permit spaces with a vertical drop of greater than 5 feet. Hot Work Performing hot work in a confined space can be very hazardous. No hot work will be performed by any CBP employee, or other party performing work for CBP, unless a Marine Chemist (for a vessel) or a Certified Industrial Hygienist (land-based activities) has evaluated the confined space and determined in writing that the hot work can be undertaken safely. CBP offices that inspect or board marine vessels shall develop a list of Marine Chemists in the local area that can be hired when needed. Arrangements should be made in advance to contract with these firms when hot work is considered. Contractors or National Guard Employees If contractors or the National Guard perform work for the CBP in a permit-required confined space, they must be informed of any potential fire, explosion, health or safety hazard of that confined space which are reasonably determinable. They must also be informed of the local permit space program requirements and other applicable safety rules of the local CBP office. Contractors may have and use their developed procedures for confined space entry if the procedures are at least as effective and protective as CBP requirements, and meet all OSHA requirements. 136

13 AP Annual Review AP11.8. Respiratory Protection. Every office shall review their canceled permits, standard operating procedures, and written permit-required confined space entry program, at least annually, and revise the program when necessary. If mechanical ventilation of the space cannot be provided, or cannot adequately assure the employeeʼs safety, appropriate respiratory protection must be provided. However, in all cases the space will be made safe for the worker, not the worker safe for the space. In the unlikely situation where respirators must be used, a written Respiratory Protection Program must be developed and all requirements of the American National Standards Instituteʼs Practices for Respiratory Protection, ANSI Z88.2 and OSHA 29 CFR must be met before an employee can be required to wear a respirator. All written Respiratory Protection Programs must be sent to the Safety and Occupational Health Branch for review and approval prior to implementation. For respirator information, refer to Appendix 14 of this handbook. AP11.9. Recordkeeping. Records will be maintained in the port, SAIC, RAIC, etc., office for a minimum of 3 years (except atmospheric test results must be maintained for 30 years). These records include: Training: Training documentation must include each employeeʼs name, the signatures or initials of the trainers, and the dates of training. This documentation must be locally available for compliance inspection. Training shall also be entered into TRAEN. Inspection of equipment: Date of the inspection, and the name of the employee conducting the inspection. Maintenance of equipment: Testing, calibration, and all other pertinent information. Calibration of equipment must be maintained in accordance with the equipment manufacturerʼs recommendations. Atmospheric test results (the permit) are considered employee exposure records by 29 CFR , and must be kept for 30 years. The record must include the date and location of the entry, testerʼs name, type of test equipment used, manufacturer, and the results. AP References. OSHA Standard 29 CFR ; ANSI Z

14 PERMIT-REQUIRED CONFINED SPACE ENTRY PROGRAM PORT OF (SAMPLE) 138

15 TABLE OF CONTENTS Item Page Scope and Application Coordination General Requirements Permit-Required Confined Space (PRCS) Program A. General (1) Acceptable Entry Conditions (2) Isolating the Permit Space (3) Purging, Inerting, Flushing or Ventilation Permit Spaces (4) External Hazards (5) Verifying Acceptable Conditions B. Evaluating Permit Space Conditions (1) General (2) Testing and Monitoring (3) Procedures for Atmospheric Testing (4) Prior to Re-entry Testing (5) Access to Test Results C. Attendants (1) General (1) Duties D. Entrants (1) General (2) Duties E. Entry Supervisor (1) General (2) Duties F. Permit System (1) General (2) Requirements (3) Permit Posting, Retention, and Annual Review G. Training (1) General (2) Requirements

16 TABLE OF CONTENTS (continued) H. Rescue and Emergency Services (1) General (2) On-Site Rescue Services (3) Off-Site Rescue Services (4) Non-Entry Rescue Alternate Procedures for Entering Permit Confined Spaces To Reclassify a Permit Space to a Non-Entry Permit Confined Space Contractors References Figure AP Recommended Equipment Inventory List Figure AP11-2 Step by Step Flow Chart Figure AP11-3 Confined Space Decision Tree (Note to Plan Writer: Consider adding here as additional appendices the CBP forms developed for confined space entry (i.e., CF-515, 557, 558), as additional references for the reader. If added, describe or reference these appendices in appropriate sections of the policy, and add to the Table of Contents above.) 140

17 SCOPE AND APPLICATION This Permit-Required Confined Space (PRCS) Program is designed to protect authorized CBP employees who must enter confined spaces and may be exposed to hazardous atmospheres, engulfment hazards, conditions which may trap or asphyxiate due to converging or sloping walls, or contains any other safety or health hazard. Confined spaces are potentially very hazardous and/or lethal work environments and should only be entered if absolutely necessary and in strict accordance with this written program. Asphyxiation is the leading cause of death in confined spaces. There have also been cases when workers entering confined spaces have been injured, crushed, or battered by moving parts inside vessels, mixers, etc. The physical nature of confined spaces easily generates highly toxic and harmful environments and in some cases immediately dangerous to life and health (IDLH) situations unless adequate precautions are taken. Often, multiple fatalities occur in confined space as a result of attempts to rescue coworkers, with additional workers becoming fatality victims. This Permit-Required Confined Space (PRCS) Program covers all employees who enter permit confined spaces and contains the practices and procedures for their safe entry. This PRCS Program describes the measures necessary to: (1) prevent unauthorized entry into permit-required confined spaces, (2) identify and evaluate permit space hazards, and (3) implement the means, procedures, and practices necessary for safe entry operations. COORDINATION The PRCS coordinator is who is responsible for maintaining a current copy of the program and making it available to all employees. Specific questions about the program and interpretations should be directed to the PRCS Program coordinator. GENERAL REQUIREMENTS This PRCS program covers the safety requirements, including a permit system, for employees to enter confined spaces, designated as permit-required confined spaces (permit spaces) which: pose special dangers for entrants; have configurations hampering efforts; which require protection for entrants from serious hazards including atmospheres which are or may be: toxic, explosive, or asphyxiating; and which have other hazards. 141

18 PERMIT-REQUIRED CONFINED SPACE (PRCS) PROGRAM The workplace has been thoroughly evaluated to identify the permit-required confined spaces that employees may be required to enter during the course of work. The complete list of all the PRCSʼs or anticipated PRCSʼs for is located (Note to Plan Writer: Identify here the confined spaces that are commonly encountered that may be entered). A. General This permit-required confined space program is designed to prevent unauthorized entry into permit confined spaces, identify and evaluate hazards, and establish procedures and practices for safe entry including testing and monitoring. The program requires: (1) extensive procedures for safe entry to include atmospheric testing and ventilation; (2) an attendant stationed outside permit spaces during entry; (3) procedures to summon rescuers and prevent unauthorized personnel from attempting rescue; and (4) a system for preparing, issuing, using and canceling entry permits. It also includes a review of the permit program at least annually and additionally as necessary. The following measures have been implemented as necessary to prevent unauthorized employee entry into permit spaces. All affected employees have been informed through initial safety training about the characteristics and presence of permit spaces. Some permit spaces are posted with danger signs. However, with the inspection of other property, confined spaces are most often not properly posted. Therefore, each employee must know what a permit space is, the usual hazards involved, and what precautions are required to ensure safe entry so they can help ensure their own protection. The following means, procedures, and practices necessary for safe permit space entry operations have been implemented: 1. Acceptable Entry Conditions Acceptable entry conditions must exist before allowing entrants to enter a permit entry space. OSHA considers unacceptable entry conditions as an oxygen deficiency (less than 19.5%) or increased oxygen concentration (greater than 23.5%); presence of toxic materials (above 50% of the permissible exposure limit); flammable gases and vapors (10% or greater of the lower flammable limit); engulfment, configurational or any other recognized hazards. CBP has adopted a more protective acceptable range for atmospheric hazards as: oxygen content between 20%-21%; carbon monoxide less than 25 parts per million (ppm); less than 2% lower flammable limit; less than 2 ppm hydrogen sulfide; and less than one-half of the OSHA or other industry accepted permissible exposure limit for any other contaminant. CBP employees will not enter permit spaces until all hazards have been corrected and no atmospheric hazards (as defined above) are present. 142

19 2. Isolating the Permit Space All hazardous energy sources associated with permit spaces that may expose entrants to potential injury are isolated, locked out and/or tagged out prior to entry. (Note to Plan Writer: Describe here additional local procedures and equipment to ensure hazard energy sources are addressed.) 3. Purging, Inerting, Flushing, or Ventilating Permit Spaces All permit entry spaces are thoroughly purged, inerted, flushed, and/or ventilated as necessary to ensure the elimination and/or control of all hazards or potential hazards that may cause entrants injury and/or illness. (Note to Plan Writer: Describe here additional local procedures to ensure this element is addressed.) 4. External Hazards Pedestrian, vehicle, or other barriers are provided as necessary to protect entrants from external hazards. (Note to Plan Writer: Describe here additional local procedures to ensure this element is addressed.) 5. Verifying Acceptable Conditions Conditions in permit spaces are tested and monitored throughout entry as necessary to ensutre that they are acceptable for the duration of the authorized entry. Employees will immediately leave the permit space when any gas monitor alarm set points are reached. (Note to Plan Writer: Describe here local procedures to ensure this element is addressed.) B. Evaluating Permit Space Conditions Permit space conditions are evaluated (tested/monitored) when entry operations are conducted as follows: 1. General The entry conditions in the permit space are thoroughly tested to determine if acceptable entry conditions exist before entry is authorized to begin. If isolation of the space is infeasible because the space is large or is part of a continuous system (such as a sewer or large undefined area), pre-entry testing is performed to the extent feasible before entry, and entry conditions are continuously monitored during work inside the space. Otherwise, tests and monitoring are conducted in permit spaces as necessary to determine if acceptable entry conditions are being maintained during the course of entry operations. 2. Testing and Monitoring The accuracy of testing and monitoring equipment may be significantly affected under various conditions of humidity, pressure, temperature, or by the presence of interfering chemicals. However, if the equipment is properly selected, calibrated, maintained and operated by well trained employees, the confined space testing and monitoring needs can be effectively met. All persons performing tests and monitoring for permit space entry have been properly trained in the use of and limitations of the following testing and monitoring equipment. (Note to Plan Writer: List the equipment, describe the proper use, and add any site-specific details.) 143

20 3. Procedures for Atmospheric Testing (a) Prior to entry: The atmosphere of a confined space must be analyzed or tested prior to entry. A rigid probe should be used for horizontal spaces such as compartments behind false walls. Extension tubing and a pump will be used for vertical spaces such as top entry tanks. Testing will proceed in 4 foot increments in the directions of travel. Ensure enough time during testing to allow the contaminated air to travel through the extention tubing to the instrument (know pump flow rate and distance). Ensure that all levels of the space are tested. The atmosphere may vary greatly throughout the space. The testing must be accomplished by an individual trained in, and familiar with, the use of the instrument. (b) Testing while in space: The atmosphere of a permit space may change. Therefore, the space should be continuously monitored while the space is occupied. If continuous monitoring is not possible, the atmosphere in the space must be rechecked periodically as deemed necessary during entry. 4. Prior to re-entry testing: Anytime the space is evacuated, it must be re- tested prior to re-entry. 5. Access to Test Results C. Attendants (a) Each authorized entrant or that employeeʼs authorized represenative shall be provided the opportunity to observe the pre-entry and any subsequent testing or monitoring of confined spaces. (b) Any authorized entrant may require a reevaluation of the permit space (or questionable space) any time the entrant or representative has reason to believe that the evaluation of the space may not have been accurate. (c) Immediately provide each authorized entrant or that employeesʼ authorized representative with the results of any testing upon request. 1. General At least one attendant is required outside the permit space into which entry is authorized for the duration of the entry operation. 2. Duties All attendants are required to: (a) Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure. (b) Be aware of possible behavioral effects of hazard exposure to the entrants. (c) Continuously maintain an accurate count of entrants in the permit space and ensure accurate identification of authorized entrants. (d) Remain outside the permit space during entry operations until relieved by another attendant (once properly relieved, they may participate in other permit space activities including rescue activities if properly trained and equipped). 144

21 (e) Communicate with entrants as necessary to monitor entrant status and alert entrants of the need to evacuate. (f) Monitor activities inside and outside the space to determine if it is safe for entrants to remain in the space and order the entrants to immediately evacuate if: the attendant detects a prohibited condition, detects entrant behavioral effects of hazard exposure, detects a situation outside the space that could endanger the entrants; or if the attendant cannot effectively and safely perform all the attendant duties. (g) Summon rescue and other emergency services as soon as the attendant determines that entrants need assistance to escape the permit space hazards. (h) Take the following action when unauthorized persons approach or enter a permit space while entry is underway: (i) (j) D. Entrants (1) Warn the unauthorized persons that they must stay away from the permit space, (2) Advise the unauthorized persons that they must exit immediately if they have entered the space, and (3) Inform the authorized entrants and the entry supervisor if unauthorized persons have entered the permit space; Perform non-entry rescues as specified by pre-established rescue procedures and entry supervisor; and Not perform duties that might interfere with the attendantʼs primary duty to monitor and protect the entrants. (k) (Note to Plan Writer: Add any additional duties assigned to the attendant(s) or site-specific information pertinent to this section.) 1. General All entrants must be authorized by the entry supervisor to enter permit spaces, have received the required training, use the proper equipment, and observe the entry procedures and permit. 2. Duties All entrants are required to: (a) Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure; (b) Properly use the equipment required for safe entry; (c) Communicate with the attendant as necessary to enable the attendant to monitor the status of the entrants and to enable the attendant to alert the entrants of the need to evacuate the space if necessary; (d) Alert the attendant whenever: the entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or any prohibited condition is detected; and 145

22 (e) Exit the permit space as quickly as possible whenever: the attendant or entry supervisor gives an order to evacuate the permit space, the entrant recognizes any warning sign or symptom of exposure to a dangerous situation, the entrant detects a prohibited condition, or an evacuation alarm activated. (f) E. Entry Supervisors 1. General (Note to Plan Writer: Add any additional duties or expectations of the entrant and site-specific information pertinent to this point.) Entry supervisors are responsible for the overall permit space entry and must coordinate all entry procedures, tests, permits, equipment and other relevant activities. 2. Duties All entry supervisors are required to: (a) Know the hazards that may be faced during entry, including information on the mode, signs, or symptoms, and consequences of the exposure; (b) Verifiy, 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; (c) Terminate the entry and cancel the permit when the entry is complete or there is a need to terminate the permit; (d) Verify that rescue services are available and that the means for summoning them are operable; (e) Remove unauthorized persons who enter or attempt to enter the space during entry operations; and (f) Determine that entry operations remain consistent with the permit terms and that acceptable entry conditions are maintained. (g) (Note to Plan Writer: Add any additional duties required of the entry supervisor(s) or site-specific information pertinent to this section.) F. Permit System 1. General In cases where hazards of a space cannot be thoroughly evaluated, or are detected, prior to entry, an entry permit is required. The entry permit is a vital part of the permit space entry program and documents that all required measures have been taken to control or eliminate the hazards and ensure entrant safety. The permit verifies completion of items listed in the permit. All pertinent safety requirements must be recorded on the permit including the methods and results for isolation, ventilation, tests and monitoring, personal protective equipment, and other equipment necessary for entrant safety. The permit shall be kept at 146

23 the job site for the duration of the job. If circumstances cause an interruption in the work or a change in the conditions for which the entry was approved, a new permit must be completed. 2. Requirements The following information must be recorded (documented) on the entry permit (CF-515 is the CBP Confined Space Entry Permit form). (a) Identification of permit space to be entered, purpose of the entry, and the date and authorized duration of the entry permit; (b) Names of authorized entrants (or other suitable tracking system); (c) Current attendantsʼ names; (d) Entry supervisorsʼ name (signature), including original authorizing supervisor, (e) Hazards of the space; (f) Measures used to isolate the space and to eliminate or control the space hazards, before entry; (g) Acceptable entry conditions; (h) Results of initial and periodic tests accompanied by the names, or initials, of the testers and time of the tests; (i) (j) Available rescue and emergency services and how to summon them; Communication procedures used by entrants and attendants to maintain contact during entry; (k) Equipment, such as personal protective equipment, alarm systems and rescue equipment, to be provided; (l) Any other pertinent information necessary to ensure entrant safety; and (m) Any additional permits, such as hot work, that have been issued to authorize work in the space. 3. Permit Posting, Retention, and Annual Review (a) The completed permit shall be made available at the time of entry to all authorized entrants or their authorized representatives, by posting it at the entry portal or by any equally effective means, so that entrants can confirm pre-entry preparations have been made. (b) All cancelled and completed permits shall be retained to allow for an annual review of the permit space program. (c) The permit space program shall be updated annually based on review of the cancelled permits from the previous 12 months. The written program and standard operating procedures shall be revised as necessary to improve the program based on review of the types of spaces encountered and review and correction of any issues or problems that occurred with the entries. If no entries are performed during the 12-month period, no formal review is necessary. 147

24 4. (Note to Plan Writer: Describe here any additional local entry procedures and requirements developed by the port or relevant to this section.) G. Training 1. General All entry supervisors, attendants, and entrants are properly trained initially and refresher training is provided when duties and space hazards change or whenever an evaluation determines inadequacies in the employeesʼ knowledge. Training establishes employee proficiency in the duties required by this policy, OSHA requirements, and will introduce new or revised procedures as necessary. 2. Requirements Specific training requirements include, but are not limited to: (a) Each affected employee is trained on the specific duties required of that employee prior to being assigned to a confined space entry procedure. (b) Training is provided: (1) Before employee is first assigned permit space entry duties; (2) Whenever there is a change in permit space operations that present a new hazard unknown by the employee; (3) Whenever there is reason to believe either there are deviations from the entry procedures or inadequacies in an employeeʼs knowledge or use of the procedures. (c) The training establishes employee proficiency in the required duties and introduces new or revised procedures, as necessary. (d) The training is certified and contains each employeeʼs name, signatures or initials of the trainers, and training dates. (e) The training certification is available for inspection by employees and their authorized representatives by contacting: (Note to Plan Writer: Indicate here the person or group who could be contacted locally to review training documentation material.) (f) (Note to Plan Writer: Provide and add additional details of specific training required for employees for confined space entry, such as pre-entry meetings to determine roles/responsibilities, etc.) H. Rescue and Emergency Services 1. General Rescue and emergency services are provided (Note to Plan Writer: Describe on-site and/or off-site rescue services. The policy should describe in detail the specific rescue and emergency service(s) that will be used.) 2. On-Site Rescue Services (optional if used, if not omit) Each member of the rescue service has been provided with, and is trained to use properly, the personal protective equipment and rescue equipment necessary for making rescues from permit spaces. This equipment includes, but is not limited to: 148

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