PERMIT-REQUIRED CONFINED SPACE ENTRY PROGRAM

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1 PERMIT-REQUIRED CONFINED SPACE ENTRY PROGRAM Dave Gelhar Dave Gelhar/ Date President Dan Schmid Pam Schmid Dan Schmid / Date Pam Schmid / Date Safety Director Quality Director

2 Contents STATEMENT OF POLICY... 3 RELATED... 3 SCOPE AND APPLICATION... 3 DEFINITIONS... 3 PROGRAM ELEMENTS Permit-required confined space evaluation, inventory, and labeling Entry procedures Entry permits and authorization Contractors Responsibilities of entrants, attendants and supervisors Equipment Training and communication Employee participation PROGRAM EVALUATION APPENDIX A CONFINED SPACE EVALUATION FORM APPENDIX B CONFINED SPACE EVALUATION DECISION MAKING FLOW CHART APPENDIX C INVENTORY OF PERMIT-REQUIRED CONFINED SPACES APPENDIX D EMPLOYEES TRAINED AND AUTHORIZED TO AUTHORIZE CONFINED SPACE ENTRY PERMITS APPENDIX E PERMIT REQUIRED CONFINED SPACE ENTRY PERMIT APPENDIX F INFORMATION PROVIDED TO CONTRACTORS Page 2 of 25

3 STATEMENT OF POLICY SpecSys is committed to maintaining a safe and healthy work environment. Managers and supervisors are responsible for the establishment and maintenance of good health and safety practices in their respective units. SpecSys employees and outside contractors must be properly trained and equipped to work in hazardous conditions such as permit-required confined spaces. This program requires that all permit-required confined spaces to be identified, evaluated, classified, and labeled. Written entry procedures and an entry permit system will be developed and implemented for all work involving entry into these spaces. The hazards and required precautions shall be communicated to all appropriate staff. RELATED Permit-Required Confined Space Program Requirement Summary for Operations Personnel Lockout/Tagout Program SCOPE AND APPLICATION This program contains requirements for practices and procedures to protect employees from the hazards of entry into permit-required confined spaces (see definitions ). Portions of this program apply wherever there are Permit-Required Confined Spaces, regardless of whether or not these spaces are entered by employees or other persons such as contractors. Additional requirements apply whenever employees or contractors enter these spaces. DEFINITIONS Non-Permit Required Confined Space means a space that meets the definition of confined space but does not meet the definition of a permit-required confined space because it does not have the potential to contain any hazard capable of causing serious physical harm. Attendant means a person trained in emergency rescue procedures assigned to remain outside permit-required confined spaces and to be in communication with and assisting those working inside. Authorized Entrant means a worker authorized to enter a permit-required confined space. Page 3 of 25

4 "Confined space" means a space that: Is large enough and so configured that an employee can bodily enter and perform assigned work; and Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and Is not designed for continuous employee occupancy. Engulfment means the surrounding of a person by a liquid or finely-divided (flowable) solid substance. The substance may cause death by filling or plugging the person s respiratory system or might exert enough force on the body to cause death by strangulation, constriction, or crushing. Entry means the passing of any part of a person s body through an opening into the space. Entry Permit means a written document that allows controlled entry into a permitrequired confined space; it also contains essential information to ensure a safe entry. Entry Supervisor means a person who is responsible for planning a confined space entry by determining if acceptable entry conditions are present, authorizing entry, overseeing entry operations, and terminating work. Hazardous atmosphere" means an atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a permit space), injury, or acute illness from one or more of the following causes: Flammable gas, vapor, or mist in excess of 10% of its lower flammable limit (LFL); Airborne combustible dust at a concentration that meets or exceeds its LFL; NOTE: This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (1.52 m) or less. Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent; Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in Subpart G, Occupational Health and Environmental Control, or in Subpart Z, Toxic and Hazardous Substances, of 29 CFR 1910 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 of ability to self-rescue, injury, or acute illness due to its health effects is not covered by this provision. Any other atmospheric condition that is immediately dangerous to life or health. Page 4 of 25

5 Hot Work means any work in a confined space that requires a flame or spark or produces sufficient heat to cause auto ignition. This includes burning, welding, hot riveting, cutting, drilling, sanding, abrasive blasting, and space heating. Hot Work Entry Permits are required. Isolation means a process in which the confined space is removed from service and is completely protected against potential hazards through blanking off piping, lockout procedures, mechanical blockage, or disconnecting linkage. "Permit-required confined space (permit space)" means a confined space that has one or more of the following characteristics: Contains or has a potential to contain a hazardous atmosphere; Contains a material that has the potential for engulfing an entrant; Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or Contains any other recognized serious safety or health hazard. Rescue Service means the personnel designated to rescue workers from permitrequired confined spaces. Retrieval System means retrieval lines, chest or full-body harnesses, wristlets, and lifting devices or anchors, used for non-entry rescue of persons from permit-required confined spaces. Testing means the process used to identify and evaluate confined space hazards. Testing includes specifying the tests that are to be performed in the confined space. PROGRAM ELEMENTS 1. Permit-required confined space evaluation, inventory, and labeling 1.1 General. All confined spaces shall be evaluated using the confined space evaluation form in appendix A. The purpose of the evaluation is to: Determine whether or not the space is a permit-required confined space; and If so; o Evaluate the hazards that may be encountered in the space, including hazards that are created or exacerbated by the work to be performed. o Classify the space into one of the categories described in section 1.2 (Note: It is possible that a space may be classified one way under one set Page 5 of 25

6 of entry circumstances, and another way under different circumstances) o Collect information on the hazards to facilitate the development of safe entry procedures as described in section 2. o Determine whether or not employees or contractors will be permitted to enter the spaces. The decision making flow chart found in Appendix B may be consulted in the course of this evaluation. 1.2 Classifying permit-required confined spaces. Once identified, all permitrequired confined spaces will be classified into one of the following classifications: Type Description 1 These are permit-required confined spaces that can not be classified as type 2 or 3. 2 These are permit-required confined spaces in which the only hazard posed is an actual or potential hazardous atmosphere and it can be demonstrated with documented monitoring data that continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry. These are described at 29 CFR (c)(5). 3 These are permit-required confined spaces which pose no actual or potential atmospheric hazards and all hazards within the space are temporarily eliminated without entry into the space. In effect, the space is temporarily reclassified from permit-required to non-permit required. Control of atmospheric hazards through forced air ventilation does not constitute elimination of the hazards. These are described at 29 CFR (c)(7). 1.3 Inventory. The results of the evaluations discussed in section 1.2 shall be used to develop a comprehensive, written inventory of all permit-required confined spaces and their classifications. The Permit-Required Confined Space Inventory form in Appendix C shall be used. 1.4 Decision to allow or prohibit entry into spaces. Based on the data collected during the evaluation, management will make a decision as to whether or not employees or contractors will be permitted to enter permit-required confined spaces. This decision may be made on a space-by-space basis, or as a blanket policy. If employees will not be permitted to enter permit spaces, all aspects of section 1 ( Permit-required confined space evaluation, inventory, and labeling ) and section 4 ( contractors ) shall apply, as applicable. Effective measures shall be provided to ensure employees do not enter prohibited spaces. If employers will be permitted to enter permit spaces, all sections of this program shall apply, as applicable based on the classification of the space. Page 6 of 25

7 1.3 Restriction of entry. If the evaluation determines that the workplace contains permit-required confined spaces, exposed employees shall be informed by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed. A sign reading DANGER PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER or using other similar language shall be used. 1.4 Reevaluating/reclassifying spaces. A Permit-Required Confined Space shall be reevaluated when/if there are changes in the use or configuration that might change or increase the hazards to entrants. The purpose of this reevaluation is to: Determine if these changes have an effect on the classification of the space; Identify any necessary changes to entry procedures, etc. A permit-required space may also be reevaluated/reclassified as non-permit required or as another class of permit-required space, when/if it can be demonstrated through documented, historical objective data (i.e. expired permits and atmospheric testing) that hazards are non-existent. 1.5 Responsibility. It is the responsibility of Plant Manager and/or Safety Director to oversee the evaluation, classification, and development of the Permit-Required Confined Space inventory. 2. Entry procedures 2.1 General. Formal, written entry procedures shall be developed and utilized for each permit-required confined space into which employees are allowed to enter. A single, written procedure may be developed for an entire class of permit-required confined spaces, when/if those spaces have identical or substantially similar hazards, required precautions, etc. and a single procedure can be written which adequately addresses any subtle differences in hazards, requirements, etc. The specific requirements for procedure content will vary, depending on the type/classification of the space at hand (see below). However, at a minimum, all procedures shall address the following considerations: Actual or potential hazards of the space, including hazards that are created, or exacerbated by the work to be performed (i.e. hot work); Specifying acceptable entry conditions to be maintained throughout the entry; Instructions for atmospheric monitoring (except type 3 spaces), including specific contaminants of concern, proper instrumentation to be used, acceptable concentrations, etc.; Instructions for ventilation (except type 3 spaces), including ventilation rates, durations, etc.; Page 7 of 25

8 Any necessary fire/explosion prevention methods, including considerations for hot work permits, explosion-proof equipment, etc. Necessary personal protective equipment, including respiratory protection (Note: use of respiratory protection may require the implementation of a respiratory protection program, meeting the requirements of 29 CFR ). Any equipment necessary to safely perform the worn including ingress and egress equipment (i.e. ladders), communication equipment, lighting, etc. 2.2 Required content for entry procedures for type 1 Permit-Required Confined Spaces. At a minimum, procedures for entering type 1 spaces must address the following: Specifying acceptable entry conditions; Providing each authorized entrant or that employee's authorized representative with the opportunity to observe any monitoring or testing of permit spaces; Isolating the permit space; Purging, inerting, flushing, or ventilating the permit space as necessary to eliminate or control atmospheric hazards; Providing pedestrian, vehicle, or other barriers as necessary to protect entrants from external hazards; Verifying that conditions in the permit space are acceptable for entry throughout the duration of an authorized entry; and Emergency procedures 2.3 Required content for entry procedures for type 2 Permit-Required Confined Spaces. At a minimum, procedures for entering type 2 spaces must address the following: 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. 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. o Oxygen content, o Flammable gases and vapors, and o Potential toxic air contaminants. Page 8 of 25

9 There may be no hazardous atmosphere within the space whenever any employee is inside the space. Continuous forced air ventilation shall be used, as follows: o An employee may not enter the space until the forced air ventilation has eliminated any hazardous atmosphere; o 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; o The air supply for the forced air ventilation shall be from a clean source and may not increase the hazards in the space. o 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. If a hazardous atmosphere is detected during entry: o Each employee shall leave the space immediately; o The space shall be evaluated to determine how the hazardous atmosphere developed; and o Measures shall be implemented to protect employees from the hazardous atmosphere before any subsequent entry takes place. o The employer shall verify that the space is safe for entry and that the preentry measures described above have been taken, through a written certification that contains the date, the location of the space, and the signature of the person providing the certification. The certification shall be made before entry and shall be made available to each employee entering the space or to that employee's authorized representative. 2.4 Required content for entry procedures for type 3 Permit-Required Confined Spaces. At a minimum, procedures for entering type 3 spaces must address the following: The procedure 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, each employee in the space shall exit. The space shall be reevaluated to determine whether it must be reclassified as a permit space. Page 9 of 25

10 3. Entry permits and authorization 3.1 General. Before entry is authorized, an entry supervisor shall document the completion of measures required by written procedures (see section 2) by authorizing an entry permit. NOTE: This section does not apply to entry into type 2 or 3 spaces as long as documentation requirements described in those sections of this program are complied with through equivalent means. 3.2 Approving the permit. Before entry begins, the entry supervisor shall sign the entry permit to authorize entry. The completed permit shall be made available to all authorized entrants or their authorized representatives, by posting it at the work site. A listing of those employees who are trained and authorized to authorize permits is found in appendix D. 3.3 Duration of the permit. The duration of the permit may not exceed the time required to complete the assigned task or job identified on the permit. The entry supervisor shall terminate entry and cancel the entry permit when: The work covered by the entry permit has been completed; or The time period covered by the permit has expired; or A prohibited or hazardous condition arises in or near the permit space. The space shall be evacuated completely and immediately when the permit is cancelled. 3.4 Retention of the permit. Each canceled entry permit shall be retained for at least one year to facilitate the review of the program. Any problems encountered during an entry operation shall be noted on the pertinent permit so that appropriate revisions to the permit space program can be made. 3.5 Permit form. The permit form found in appendix E or equivalent, shall be used. 4. Contractors 4.1 General. When employees of another employer (contractors) perform work that involves permit space entry, location staff and authorized representatives from the contractor organization shall conduct a pre-task meeting, to review the information found in appendix F. Page 10 of 25

11 4.2 Documentation. Documentation that the steps outlined above have been completed, shall be documented using the form found in Appendix F. Records shall be retained for one year, and used in the annual program review. 4.3 Responsibility. It is the responsibility of Plant Manager and/or Safety Director to ensure that the requirements of this section are complied with. 5. Responsibilities of entrants, attendants and supervisors 5.1 General. An attendant and entry supervisor will be required for all entries into type 1 Permit-Required Confined Spaces. The use of attendants and entry supervisors is recommended for entry into type 2 and 3 spaces, but is not mandatory. 5.2 Responsibilities of entrants. Employees who enter and work in permit-required confined spaces shall have the following responsibilities: Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure; Properly use equipment; 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; Alert the attendant whenever: o The entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or o The entrant detects a prohibited condition; and Exit from the permit space as quickly as possible whenever: o An order to evacuate is given by the attendant or the entry supervisor, o The entrant recognizes any warning sign or symptom of exposure to a dangerous situation, o The entrant detects a prohibited condition, or o An evacuation alarm is activated. 5.3 Responsibilities of attendants. Employees who serve as attendants during Permit-Required Confined Space entries shall have the following responsibilities: 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 accurately identifies who is in the permit space; Page 11 of 25

12 Remains outside the permit space during entry operations until relieved by another attendant; NOTE: When the procedure allows attendant entry for rescue, attendants may enter a permit space to attempt a rescue if they have been trained and equipped for rescue operations and if they have been relieved as. Communicates with authorized entrants as necessary to monitor entrant status and to alert entrants of the need to evacuate the space; 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; o If the attendant detects a prohibited condition; o If the attendant detects the behavioral effects of hazard exposure in an authorized entrant; o If the attendant detects a situation outside the space that could endanger the authorized entrants; or o If the attendant cannot effectively and safely perform all the duties required under this section; 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: o Warn the unauthorized persons that they must stay away from the permit space; o Advise the unauthorized persons that they must exit immediately if they have entered the permit space; and o 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. 5.4 Duties of entry supervisors. Employees who serve as entry supervisors during Permit-Required Confined Space entries shall have the following responsibilities: Knows the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure; Verifies, 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; Terminates the entry and cancels the permit; Verifies that rescue services are available and that the means for summoning them are operable; Removes unauthorized individuals who enter or who attempt to enter the permit space during entry operations; and Page 12 of 25

13 Determines, 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. 6. Equipment 6.1 General. Procedures described in section 2 of this program shall outline the equipment required to work safely within Permit-Required Confined spaces (regardless of type). This includes, but is not limited to: Atmospheric testing and monitoring equipment; Ventilating equipment needed to obtain and maintain acceptable entry conditions; Communications equipment; 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; Equipment, such as ladders, needed for safe ingress and egress by authorized entrants; Rescue and emergency equipment 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. 6.2 Cost. All required equipment shall be provided to employees free of charge. 6.3 Maintenance and calibration. All equipment (specifically atmospheric monitoring equipment) shall be maintained, calibrated, serviced, inspected and used, as directed by the manufacturer. 6.4 Approved equipment. Equipment shall be approved for the use at hand, specifically with regard to the equipment approval for hazardous environments (i.e. spaces which may contain explosive levels of gas, dust, fibers, etc.). A statement of approval shall be clearly legible on the equipment. 6.5 Emergency planning and response General. Formal emergency response plans must be developed when employees enter type 1 permit-required confined spaces. Emergency planning and response measures must be documented in the entry procedures. Page 13 of 25

14 6.5.2 Designating external emergency service providers to provide emergency response. If local public safety services (i.e. local police and fire) are designated to provide confined space rescue, the following steps shall be taken. The prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified, shall be evaluated. Note: What will be considered timely will vary according to the specific hazards involved in each entry. For example, 29 CFR , 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. 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; Select a rescue team or service from those evaluated that: o Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified; o Is equipped for and proficient in performing the needed rescue services; o Inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site; and o 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. Note: Non-mandatory Appendix F of 29 CFR contains examples of criteria which can be used in evaluating prospective rescuers Designating employees to provide emergency response. If employees are designated to provide permit space rescue and emergency services, the following steps shall be taken: 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 employer must 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). At least one member of the rescue team or service holding a current certification in first aid and CPR shall be available during entry operations; and 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. Page 14 of 25

15 6.5.4 Facilitating 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 shall meet the following requirements. 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 employer 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 it can be demonstrated that 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 deep Material Safety Data Sheet. If an injured entrant is exposed to a substance for which a Material Safety Data Sheet (MSDS) or other similar written information is required to be kept at the worksite, that MSDS or written information shall be made available to the medical facility treating the exposed entrant. 7. Training and communication 7.1 General. Each employee covered by this program shall receive training which complies with this section. Upon completion of training, employees must have the understanding, knowledge, and skills necessary for the safe performance of the duties assigned to them. 7.2 Cost of training. Training shall be provided at no cost to the employee. 7.3 Frequency of training. Training must be provided to an employee before initial assignment to a workplace where the employee may be routinely exposed to a hazardous substance, harmful physical agent, or infectious agent. Additional training must be provided to an employee before the time the employee may be routinely exposed to any additional hazardous substances, harmful physical agents, or infectious agents. Training updates must be repeated at intervals of not greater than one year. Training updates may be brief summaries of information included in previous training sessions. Page 15 of 25

16 7.4 Content of training. At a minimum, training shall consist of the following: The nature of Permit-Required Confined Space hazards that may be encountered in/around the spaces to which the employee may be exposed; The precautions required to control those hazards and maintain acceptable entry conditions; Proper calibration, operation, maintenance, inspection of all equipment involved in entry; Responsibilities of entrants, attendants, supervisors; The purpose, importance, and proper application of the entry procedures and permits; Emergency procedures; A brief review of this program, as well as the OSHA regulation. 7.5 Records of training. Records of training shall be maintained, retained for three years, and made available, upon request, for review by employees and representatives of the Office of Occupational Health and Safety. At a minimum, training records will include: the dates training was conducted; the name, title, and qualifications of the person who conducted the training; the names and job titles of employees who completed the training; and a brief summary or outline of the information that was included in the training session. 7.6 Unacceptable forms of training. The following types of training, by themselves, do not constitute training, and do not comply with this program or the regulation: Giving an employee a data sheet, package insert, reference manual or any other printed material to read. Watching video or computer-delivered presentations, especially when the material in the video is not specific to the operation and hazards at hand. Any type of training which does not include an opportunity for employees to ask questions to ensure they understand the information presented to them. Audiovisuals, interactive videos, printed materials, etc., may be used as a component of the ERTK training program if they are supplemented by specific information related to the employees' job duties and related exposures, and if employees are permitted to ask questions and have them answered. 7.7 Responsibility. It is the responsibility of Plant Manager and/or Safety Director to ensure that the requirements of this section are complied with. Page 16 of 25

17 8. Employee participation 8.1 General. Management shall consult with affected employees and their authorized representatives on the development, implementation/administration, and periodic review of this program and all of its aspects. Employees shall be afforded the right to review, photocopy, and comment on all components of, and information pertaining to, this program. PROGRAM EVALUATION At least annually, a formal, documented review shall be conducted to ensure that the provisions of the current written program are being effectively implemented and that it continues to be effective. APPENDIX A CONFINED SPACE EVALUATION FORM Name of space evaluated: Number of similar/identical space & location(s): Name of evaluator(s): Date of evaluation: Description of space: Results of evaluation: Not a confined space Not a Permit-Required Confined Space Permit-Required Confined Space Type 1 Permit-Required Confined Space Type 2 Permit-Required Confined Space Type 3 Who will be permitted to enter? Complete this section only if the space is classified as a type 1, 2, or 3 Permit-Required Confined Space: Location (SpecSys employees) only Contractor employees only Page 17 of 25

18 Location and/or contractors No entry will be permitted by any person Question 1. Is this area a confined space? A confined space is defined as having all of the characteristics listed below. If you conclude that this area is not a confined space, then go to the results of evaluation section above and check not a confined space. STOP. If you conclude that this area is a confined space, then continue to the next question. Yes No Is the space large enough and so configured that a person can bodily enter and work? Yes No Does the space have a limited or restricted means of entry or exit? Yes No Is the space not designed for continuous human occupancy? Questions 2. Is this area a Permit-Required Confined Space? A permit-required confined space is defined as a confined space (see question 1) which also has one or more of the characteristics below. If you conclude that this area is not a permit-required confined space, then go to the results of evaluation section above and check not a permit-required confined space. STOP. If you conclude that this area is a permit-required confined space, then continue to the next question. Yes No Does the space contain, or have the potential to contain a hazardous atmosphere (i.e. oxygen deficiency, explosive limits, carbon monoxide, hydrogen sulfide), or pipes, ducts or other entry points for potentially hazardous substances, or will volatile chemicals be used, or will painting, sealing, or other work practices create a breathing hazard? Specify hazards: Yes No Does the space contain an engulfment hazard (i.e. sand, grain, water)? Specify hazards: Yes No Does the space have inwardly converging walls that taper downward to a smaller crosssection, or floors that slope downward that could lead to entrapment or asphyxiation? Specify hazards: Yes No Does the space contain other recognized serious hazards, such as: Mechanical hazards such as moving parts, unguarded machinery, etc. Exposed or vulnerable electrical wires or electrical equipment Gas or chemical lines Special hazards related to elevation or falling Temperature extremes/heat stress Other Page 18 of 25

19 Specify hazards: Questions 3. Is this area a Type 2 Permit-Required Confined Space? A type 2 permit-required confined space is defined as a permit-required confined space (see question 1 and 2) which meets all of the characteristics below. If you conclude that this area is not a type 2 permit-required confined space, then continue to question 4. If you conclude that this area is a type 2 permit-required confined space, then go to the results of evaluation section above and check Permit-Required Confined Space Type 2. STOP. Note that the conditional instructions found in the 2 nd and 3 rd bullets in questions 3 and 4 are inconsistent with previous questions. Please read all questions and instructions carefully. Yes No The only hazard of the permit-required confined space is a hazardous or potentially hazardous atmosphere. Yes No Continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry; Yes No There is a formal documented history of evaluations that support the conclusion above. Questions 4. Is this area a Type 3 Permit-Required Confined Space? A type 3 permit-required confined space is defined as a permit-required confined space (see question 1 and 2) which meets all of the characteristics below. If you conclude that this area is not a type 3 permit-required confined space, then continue to question 5. If you conclude that this area is a type 3 permit-required confined space, then go to the results of evaluation section above and check Permit-Required Confined Space Type 3. STOP. Note that the conditional instructions found in the 2 nd and 3 rd bullets in questions 3 and 4 are inconsistent with previous questions. Please read all questions and instructions carefully. Yes No The space has no actual or potential atmospheric hazards. Yes No All hazards within the space can be positively controlled or eliminated temporarily without entry into the space. For example, by locking out augers, and other such mechanical hazards. Questions 5. Is this area a Type 1 Permit-Required Confined Space? A type 1 permit-required confined space is defined as a permit-required confined space (see question 1 and 2) which DOES NOT meet conditions for type 2 or 3 (see questions 3 and 4). If you have identified this space as a permit-required confined space (see questions 1 and 2), AND have concluded that it is not a Type 2 or Type 3, then go to the results of evaluation section above and check Permit-Required Confined Space Type 1. STOP. Page 19 of 25

20 APPENDIX B CONFINED SPACE EVALUATION DECISION MAKING FLOW CHART Page 20 of 25

21 APPENDIX C INVENTORY OF PERMIT-REQUIRED CONFINED SPACES Name/Location(s) Classification Description Hazards Contaminants/Gases

22 APPENDIX D EMPLOYEES TRAINED AND AUTHORIZED TO AUTHORIZE CONFINED SPACE ENTRY PERMITS Employee name Job title Date of most recent training (authorization expires one year after training) Page 22 of 25

23 APPENDIX E PERMIT REQUIRED CONFINED SPACE ENTRY PERMIT General information Space to be entered: Name of entry supervisor (req. for type 1 entries): Permit start date/time Expires date/time: Name of attendant (req. for type 1 entries): Purpose of entry/work to be performed: Name(s) of entrants: Primary hazards that may be encountered (as identified in entry procedure) Hazards Acceptable entry condition (i.e. Carbon Monoxide exposure ) (continuous forced air ventilation sufficient to maintain CO levels to less than 35 parts per million) Preparation for entry (See written procedure for requirements) Entrants, attendants, supervisor, contractors - all trained in confined space safety. Done NR All have reviewed and understand entry procedure, especially anticipated hazards, Done NR acceptable entry conditions, emergency procedures. Work with contractors is coordinated. Emergency procedure: Done NR Means to communicate with entrants: Done NR Means to summon rescue: Done NR PPE/Respiratory protection to be worn: Done NR All moving parts, augers, etc. are locked and tagged out Done NR Flow of incoming material, including gases, positively controlled (i.e. pumps locked out, Done NR feedlines disconnected or blanked) Mechanical ventilation running prior to entry and continuously throughout Done NR Atmospheric testing equipment (4 gas meter, drager tubes, etc.) running Done NR Ingress/egress equipment provided Done NR Appropriate fire extinguisher provided Done NR Material Safety Data Sheet provided Done NR Hot Work Permit completed Done NR NR Not required by procedure Page 23 of 25

24 Initial pre-entry atmospheric check Person conducting test Time To be measured: Acceptable range Instrument(s) used Oxygen (O 2 ): Hydrogen Sulfide (H 2 S): Carbon Monoxide (CO): Lower Explosive Limit (LEL): Other : Other : Other : 19.5%-23.5% Less than 10 ppm Less than 35 ppm Less than 10% ppm ppm ppm Supervisor s authorization I have reviewed the relevant confined space entry procedure and verified that all necessary steps to prepare for entry have been taken. I authorize this work to begin at this point. Entry supervisor: Date/Time: Atmospheric monitoring during entry Time Oxygen Hydrogen Sulfide CO <10 ppm <35 ppm LEL <10% Other Other Other Roster of entrants(s) currently in space Name Current status Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Enter Exit Conclusion complete this section after work has concluded Permit terminated because Work was completed as planned Prohibited condition/emergency Any event that would merit a review confined space program/procedure? Yes No Was a mandatory close-out meeting held with contactors? Yes No Page 24 of 25

25 APPENDIX F INFORMATION PROVIDED TO CONTRACTORS A pre-task meeting shall be conducted prior to allowing contractors to perform any work which involves entry into permit-required confined spaces. At a minimum, the pre-task meeting shall be attended by SpecSys location staff and at least one authorized representative of the contractor organization/company. The final item in the checklist below must be completed at the conclusion of the work. Inform the contractor that the workplace contains permit-required confined spaces and the contractor is required to have a permit-required confined space program meeting the requirements of 29 CFR Contractor use of the SpecSys s program is not allowable; Conduct a review of the contractor s confined space entry program, procedures and training records to determine if they are adequate. OHS and/or DEHS are available to assist with this review; Apprise the contractor of the elements, including the hazards identified and the location s experience with the space, that make the space in question a permit space; Apprise the contractor of any precautions or procedures that have been 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 SpecSys and contractor personnel will be working in or near permit spaces; and Debrief the contractor at the conclusion of the entry operations regarding the permit space program followed and regarding any hazards confronted or created in permit spaces during entry operations. Complete Complete Complete Complete Complete Complete I acknowledge that the information above has been communicated between the parties. SpecSys staff (printed name) SpecSys staff (signature) Date Contractor staff representative (printed name) Contractor staff representative (signature) Name of contractor organization/company Date Page 25 of 25

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