CONFINED SPACES. PART 1: INTRODUCTION

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1 COFIED SPACES PART 1: ITRODUCTIO Applicability of This Module Use the following General Applicability Checklist to determine whether a rulebook and its sections apply to your operation If you answer ES to the rulebook uestion, the rulebook applies to you unless you answer ES for a rulebook exemption Once you determine that the rulebook does apply to your operation, you must answer the section uestions If a section uestion does not exist, then that section applies if the rulebook applies If you answer ES to a section uestion, that section applies to you unless you answer ES for an exemption from that section If you answer ES to a rulebook or section exemption, then the rulebook or section does not apply GEERAL APPLICABILIT CHECKLIST Rulebook: Confined Spaces RULEBOOK: Does your facility have any spaces that meet the definition of a confined space? Applies Exempt Section 2: Do you have any spaces that are permit-reuired confined spaces? OTE: This section addresses reuirements employers must meet when arranging to have contractors perform work that involves permit-reuired confined space entry Section 3: Do you have any spaces that are permit-reuired confined spaces? OTE: This section addresses the reuirements for a written permit-reuired space program Section 3 Exemption: Do you not enter confined spaces? Section 4: Do you have any spaces that are permit-reuired confined spaces? OTE: This section addresses the reuirements for an entry permit Section 4 Exemption: Do you not enter confined spaces? Section 5: Do you have any spaces that are permit-reuired confined spaces? OTE: This section addresses the duties of various personnel, and the associated training reuirements Section 5 Exemption: Do you not enter confined spaces? Section 6: Do you have any spaces that are permit-reuired confined spaces? OTE: This section addresses the reuirements for rescue operations Section 6 Exemption: Do you not enter confined spaces? Section 7: Do you have any spaces that are permit-reuired confined spaces? OTE: This section addresses the reuirements for routine review of the program Section 7 Exemption: Do you not enter confined spaces? CS/Part 1-1

2 Confined Spaces Introduction Regulatory Summary The Federal regulations that apply to permit-reuired confined spaces are found in 29 CFR In addition, many state and local governments have confined space entry programs The Occupational Safety and Health Administration (OSHA) is authorized to administer and enforce the permit-reuired confined space entry regulations Therefore, the regulated community must follow both federal and applicable state law, and any local reuirements OSHA maintains numerous Directives on the topic of confined space All Directives may be viewed on the OSHA website ( wwwoshagov), by clicking on the letter D (for Directives) in the site Index In the Directives page, search for The most relevant and current Directive that may be useful in specific compliance issues is the following: 05/05/ CPL CPL 2100 Application of the Permit-Reuired Confined Spaces (PRCS) Standards, 29 CFR Key Compliance Definitions These definitions were derived from 29 CFR (b) Acceptable entry conditions Environmental conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permit-reuired confined space entry can safely enter into and work within the space Attendant An individual stationed outside one or more permit spaces who monitors the authorized entrants and who performs all attendant s duties assigned in the employer s permit space program Authorized entrant An employee who is trained, euipped, and authorized by the employer to enter a permit space Blanking or blinding The absolute closure of a pipe, line, or duct by the fastening of a solid plate that completely covers the bore and is capable of withstanding the maximum pressure of the pipe, line, or duct with no leakage beyond the plate Confined space A space that is large enough and configured in such a way that an employee can enter and perform assigned work It also has limited or restricted means of entry or exit (eg, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces), and is not designed for continuous employee occupancy Double block and bleed The closure of a line, duct, or pipe by closing and locking or tagging two in-line valves, and by opening and locking or tagging a drain or vent valve in the line between the two closed valves Emergency An occurrence (including any failure of hazard control or monitoring euipment) or event internal or external to the permit space that could endanger entrants Engulfment The surrounding and effective capture of a person by a liuid 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 The action by which a person passes through, or any part of the person s body breaks the plane of, an opening into a permit-reuired confined space CS/Part 1-2

3 Confined Spaces Introduction Entry permit (permit) The written or printed document provided by the employer to allow and control entry into a permit space which identifies: the space; purpose for entry; date and time of authorized entry; roster of authorized entrants; designated attendant(s) and supervisor(s); the hazardous condition(s); control measures; acceptable entry conditions; atmospheric test results and certification; emergency response and communication procedures; and any other necessary permits, eg, hot-work permits Entry supervisor The person 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 Hazardous atmosphere An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to escape unaided from a permit space, injury, or acute illness from any of the following causes: flammable gases, vapors, or mists in excess of 10% of its lower flammable limit (LFL); airborne combustible dust that meets or exceeds its LFL or if the dust obscures vision at a distance eual to or less than 5 feet; atmospheric oxygen below 195% or above 235%; atmospheric concentrations of any substances that could result in employee exposures in excess of its dose or permissible exposure limits (PELs); or any other atmospheric condition immediately dangerous to life or health Hot work permit A written authorization to perform heat-generating tasks (eg, riveting, welding, cutting, burning, and heating) capable of providing a source of ignition Immediately dangerous to life or health (IDLH) Any condition that poses an immediate or delayed threat to life, would cause irreversible adverse heath effects, or would interfere with an individual s ability to escape unaided from a permit space Inerting Displacement of the atmosphere in a permit space by a noncombustible gas (eg, nitrogen) to such an extent that the resulting atmosphere is noncombustible Isolation The process by which a permit space is removed from service and completely protected against the release of energy and material into the space by such means as: 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; or blocking or disconnecting all mechanical linkages Line breaking The intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure, or temperature capable of causing injury onpermit confined space A confined space that does not contain or, with respect to atmospheric hazards, does not have the potential to contain any hazard capable of causing death or serious physical harm Oxygen deficient atmosphere An atmosphere containing less than 195% oxygen by volume Oxygen enriched atmosphere An atmosphere containing more than 235% oxygen by volume Permit-reuired confined space (permit space) A confined space that has any of the following characteristics: contains or has the potential to contain a hazardous atmosphere; contains a material that has the potential for engulfing an entrant; CS/Part 1-3

4 Confined Spaces Introduction 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 safety or health hazard Permit-reuired confined space program (permit space program) The employer s overall program for controlling and, where appropriate, for protecting employees from permit space hazards, and for regulating employee entry into permit spaces Permit system The employer s written procedure for preparing and issuing permits for entry and for returning the permit space to service following termination of entry Prohibited condition Any condition in a permit space not allowed by the permit during the period when entry is authorized Rescue service The personnel designated to rescue employees from permit spaces Retrieval system The euipment (including a retrieval line, chest or full-body harness, wristlets, if appropriate, and a lifting device or anchor) used for non-entry rescue of persons from permit spaces Testing The process by which the tests that are to be performed in the permit space are specified and the hazards that may confront entrants of a permit space are identified and evaluated CS/Part 1-4

5 COFIED SPACES PART 2: PRE AUDIT PREPARATIO Items to consider getting in advance: Written confined space entry program Additional policies and procedures related to confined space entry program Applicable OSHA Directives and Letters of Interpretation Items to have facility personnel prepare or gather in advance: Training records related to permit-reuired confined space Euipment testing records Monitoring records Job descriptions for entrants, attendants, and entrant supervisors Confined-space entry permit(s) Emergency rescue euipment and services CS/Part 2-1

6 Confined Spaces Pre audit Preparation Acronyms and Abbreviations Used in This Module % percent CFR Code of Federal Regulations CPR cardio-pulmonary resuscitation GMP good management practice IDLH immediately dangerous to life or health LFL MSDS OSHA PEL PPE lower flammable limit material safety data sheet Occupational Safety and Health Administration permissible exposure limit personal protective euipment CS/Part 2-2

7 COFIED SPACES PART 3: RULEBOOK 1 General Reuirements 11 The facility must evaluate the workplace to determine if any spaces are permit-reuired confined spaces (29 CFR (c)(1) and (c)(6)) Verify that the facility has evaluated the workplace and properly identified any permit-reuired confined spaces (29 CFR (c)(1)) OTE: The permit-reuired confined space decision flow chart in 29 CFR Appendix A can be used to aid in verification Verify that the facility has a system to re-examine the classification of a non-permit space when changes in the configuration or use might increase hazards to entrants to the level where it should be designated a permitreuired space (29 CFR (c)(6)) 12 Permit-reuired confined spaces must be identified by posting warning signs (or other effective methods) to inform employees of the existence and location of, and the danger posed by, the permit spaces (29 CFR (c)(2)) Verify that the employer posts signs warning employees against unauthorized entry into confined spaces (29 CFR (c)(2)) Verify that signs provide adeuate warning (29 CFR (c)(2)) OTE: The wording DAGER PERMIT-REQUIRED COFIED SPACE, DO OT ETER is an example of adeuate warning Verify that if signs are not posted to warn employees of the permit-reuired confined space alternative methods (training, color coding, etc) are used OTE: Ordinarily, information about permit spaces is most effectively and economically communicated through the use of signs so signs are OSHA s preferred method of warning under the standard Alternative methods, such as additional training, may be used where they are truly effective in warning all employees who could reasonably be expected to enter the space In some cases, employers may have to provide training in addition to signs, to protect employees who do not speak English or who would have difficulty understanding or interpreting signs If a space has a locked entry cover or panel, or an access door that can only be opened with special tools, the use of sign s may be unnecessary if the employer ensures that all affected employees are informed about such spaces and know that they are not to be opened without taking proper precautions, including temporary signs, to restrict unexpected or unknowing entry (OSHA Interpretation Letter, 07/22/1998) 13 If the employer decides that employees will not enter confined spaces, the employer must take effective measures to prevent employees from entering confined spaces (29 CFR (c)(3)) Verify that the employer has (29 CFR (c)(3)): evaluated and identified confined spaces per paragraph 11; posted permit-reuired confined spaces per paragraph 12; developed and implemented a program to determine the status of a non-permit reuired confined space when circumstances change that might reclassify it as a permit-reuired confined space; and developed and implemented a program for contractor entry into confined spaces, per paragraph 21 CS/Part 3-1

8 Confined Spaces Rulebook 2 Contractors 21 When the employer (host employer) arranges to have contractors perform work that involves permit-reuired confined space entry, the host employer must inform the contractor that the workplace contains permit spaces and that entry is allowed only via compliance with a permit space program (29 CFR (c)(8) and (c)(9)) Determine if the employer ensures that contractors are informed of the following (29 CFR (c)(8)): the existence of permit spaces and the reuirements to have a permit space program for entry into those spaces; the hazards of the spaces that make them permit-reuired confined spaces and the host employer's experience with the space; precautions and procedures that the employer has implemented for protection of employees in or near permit spaces where contractor personnel will be working; and coordination procedures between the host employer and contractor if both the host employer and contractor will be working in or near permit spaces to ensure the safety of both sets of employees Determine if the contractor who is retained to perform permit space entry operations also (29 CFR (c)(9)): obtains any available information regarding permit space hazards and entry operations from the employer; coordinates entry operations with the employer, when both the employer and contractor personnel will be working in or near permit spaces; informs the employer of any hazards confronted or created in permit spaces, either through a debriefing or during the entry operation; and informs the employer of the permit space program that the contractor will follow OTE: If the contractor is to follow the host employer s program, review training procedures to verify that contractor employees are appropriately trained in the host employer s procedures (GMP) Determine if the employer debriefs the contractor regarding any hazards confronted or created in permit spaces during entry operations at the conclusion of the entry operation (29 CFR (c)(8)(v)) Determine if the facility audits confined space entries made by the contractor (GMP) 3 Permit Reuired Confined Space Program 31 An employer whose employees enter permit spaces must develop and implement a written permit space program (29 CFR (c)(4), 29 CFR (d)(1) (d)(2) and (29 CFR (l)) Verify that the employer has developed a written program (29 CFR (c)(4)) Verify that the program is available to employees and authorized representatives (29 CFR (c)(4)) Verify that if properly followed, the plan implements measures necessary to prevent unauthorized entry and to identify and evaluate the hazards of permit spaces before employees enter them (29 CFR (d)(1) (d)(2)) Verify that the employer has consulted with affected employees and their authorized representatives on the development and implementation of all aspects of the permit space program, and makes all of the information developed under the program available to employees and their representatives (29 CFR (l) 32 The employer s written permit space program must include certain elements (29 CFR (d)(3) and 29 CFR (d)(6) (d)(12)) Verify that the permit space program specifies acceptable entry conditions appropriate for the types of permit spaces present at the facility (29 CFR (d)(3)(i)) Determine if the employer has developed procedures for isolating the space and, as appropriate, purging, inerting, flushing, or ventilating the permit space to eliminate or control atmospheric hazards (29 CFR (d)(3)(iii) and (d)(3)(iv)) CS/Part 3-2

9 Confined Spaces Rulebook Determine if the employer has developed effective methods to restrict pedestrian and vehicular access to the entry areas to protect entrants from external hazards (29 CFR (d)(3)(v)) Determine if the employer has established procedures for verifying that conditions in the permit space remain safe for the duration of an authorized entry (29 CFR (d)(3)(vi)) Verify that the program reuires at least one attendant to be present outside the confined space during the entry operations (29 CFR (d)(6)) OTE: Attendants may monitor more than one permit space provided that the reuired duties (listed in paragraph 53) can be effectively performed However, if this is allowed, the procedures must address how an attendant would respond to an emergency within one space while effectively carrying out the attendant duties for the other space(s) (29 CFR (d)(7)) Verify that the program defines the duties of each party (entrants, attendants, supervisors) prior to and during the entry process, including the training to be provided to each party (see section 5) (29 CFR (d)(8)) Verify that the program defines procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue (29 CFR (d)(9)) Verify that the program has a system for preparation, issuance, use, and cancellation of entry permits (see paragraphs 41 to 43) (29 CFR (d)(10)) Verify that the program addresses coordination of entry operations when employees of more than one employer are working simultaneously in or near a permit space so that they do not endanger each other (see paragraph 21) (29 CFR (d)(11)) Verify that the program has procedures for closing off a permit space and canceling the permit after entry operations have been concluded (29 CFR (d)(12)) 33 The employer must provide and maintain the euipment reuired to safely enter the permit spaces, and must ensure that employees use the euipment properly (29 CFR (d)(4)) Verify that the employer provides and maintains the following euipment for permit space entry at no cost to employees, and ensures that they use it properly (29 CFR (d)(4)): testing and monitoring euipment needed to test and evaluate entry conditions per paragraph 34; ventilating euipment needed to obtain acceptable entry conditions; communications euipment needed to communicate between entrant and attendant, as necessary for either party to update the other as to entry status and emergency conditions; personal protective euipment (PPE) as needed if feasible engineering and work practice controls do not adeuately protect employees lighting euipment needed to enable employees to see well enough to work safely and to exit the space uickly in an emergency; barriers and shields as reuired to protect entrants from potential external hazards; euipment, such as ladders, for safe entry and exit by authorized entrants; essential rescue and emergency euipment, except to the extent that is provided by external emergency responders; and any other euipment necessary for safe entry into and rescue from confined spaces 34 The confined space entry program must include monitoring of the atmosphere in the space prior to entry to as needed to ensure safe entry conditions exist before entry is authorized, and during entry to ensure as needed safe entry conditions are maintained (29 CFR (d)(5)) Verify that the testing procedures for evaluation of safety prior to entry include the following (29 CFR (d)(5)): for spaces that can be isolated: 1) testing of conditions within the confined space to determine if acceptable entry conditions exist prior to entry; and 2) testing or monitoring as necessary during entry to determine acceptable entry conditions are maintained for spaces that cannot be isolated: 1) testing to the extent feasible prior to entry; and 2) continuous monitoring to determine safe conditions during entry CS/Part 3-3

10 Confined Spaces Rulebook OTE: Although the words as necessary appear only in paragraph 29 CFR (d)(5)(ii) relating to testing during entry to ensure that acceptable conditions are maintained, OSHA has clarified that it is not necessary to conduct testing prior to entry for any type of hazardous atmosphere for which there is no source (OSHA Interpretation Letters, 3/30/99 and 8/6/07) Verify that atmospheric monitoring is conducted first for oxygen, then combustible gases and vapors, and finally for toxic gases and vapors (29 CFR (d)(5)(iii)) OTE: This order is specified because many monitors reuire sufficient oxygen in order to give an accurate reading for hazardous vapors (OSHA Interpretation Letter 3/30/99) Verify that each authorized entrant, or that employee s authorized representative, has an opportunity to observe the pre-entry and any subseuent testing or monitoring of permit spaces (29 CFR (d)(5)(ii)(C) and (F) and 29 CFR (d)(5)(iv)) Verify that the permit space is reevaluated in the presence of any authorized entrant, or that employee s authorized representative, who reuests reevaluation because he or she has reason to believe that the evaluation may not have been adeuate Verify that each authorized entrant, or that employee s authorized representative, is immediately provided with the results of any testing conducted in accordance with this paragraph Determine if monitoring euipment is properly calibrated and maintained in accordance with manufacturer s recommendations (GMP) OTE: Atmospheric testing conducted in accordance with 29 CFR Appendix B would satisfy the reuirements of this paragraph For permit space operations in sewers, atmospheric testing conducted in accordance with 29 CFR Appendix B, supplemented by 29 CFR Appendix E would satisfy the reuirements of this paragraph 35 An employer may use an alternate program in lieu of a permit-reuired confined space program under certain conditions (29 CFR (c)(5)) Verify that the following conditions are met to allow use of the alternate program, and supported by monitoring and test data (29 CFR (c)(5)(i)): The only hazard posed by the permit space is an actual or potential hazardous atmosphere OTE: If a hazardous atmosphere is detected during entry, each employee must leave the space immediately, and the space must be evaluated to determine how the hazardous condition developed, and measures must be implemented to protect employees before any subseuent entry takes place Continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry If an initial entry of the permit space is necessary to obtain the monitoring and test data, the entry is performed in compliance with the full (non-alternative) permit-reuired confined space program The determinations and supporting data of safe conditions to entry listed in the first three points of this paragraph are documented by the employer and are made available to each employee who enters the permit space 36 When using an alternate entry techniue, the employer must conduct operations according to certain specified procedures (29 CFR (c)(5)(ii)) Verify that the following steps are followed during use of alternate entry techniues (29 CFR (c)(5)(ii)): Verify that all conditions making it unsafe to remove an entrance cover are eliminated before removing the cover Ensure that all openings are promptly guarded by a railing, temporary cover or barrier that will prevent an accidental fall through the opening and that will protect employees working in the space from foreign objects entering the space Test the internal atmosphere with a calibrated direct-reading instrument for the following conditions in the order given: 1) oxygen content; 2) flammable gases and vapors; and 3) potential toxic air contaminants Verify that there is no hazardous atmosphere within the space when any employee is inside the space CS/Part 3-4

11 Confined Spaces Rulebook Continuous forced air ventilation, normally used to eliminate the occurrence of hazardous atmosphere, must be used as follows: 1) Employees may not enter into the space until the hazardous atmosphere has been eliminated by ventilation 2) The employer must direct the forced air ventilation in the immediate areas where employees are present and must continue ventilating the space until all employees have left the space 3) The employer must supply a clean source of forced air and may not increase the hazards in the space The employer must verify and document that the space is safe for entry and that all pre-entry measures discussed above have been completed through use of a written certification that contains the date, location of the space, and the signature of the person providing the certification This must be made available to each employee entering the space The atmosphere within the space must be periodically tested as necessary to ensure that the forced air ventilation is effective to prevent accumulation of a hazardous atmosphere If a hazardous atmosphere is detected, each employee must immediately leave the space When a hazardous atmosphere is detected the following steps must be taken: 1) The space must be evaluated to determine why the forced air ventilation was ineffective 2) Measures must be taken to protect employees from hazardous atmospheres before any subseuent entry takes place 37 The facility can reclassify a permit space as a non-permit space under certain conditions (29 CFR (c)(7)) Determine if the facility reclassifies permit spaces as non-permit spaces (this is typically done under conditions of major maintenance when significant disassembly of euipment occurs) If so, verify that such classification occurs only under the following circumstances (29 CFR (c)(7)): There are no actual or potential atmospheric hazards and all other hazards (electrical, etc) within the space are eliminated and remain eliminated OTE: Control of atmospheric hazards through forced air ventilation does not constitute elimination of hazards If it is necessary to enter the permit space to eliminate hazards to reach this condition, the entry procedures outlined in the employer s permit program must be followed If testing and inspection during initial entry and review demonstrate that the hazards within the permit space have been eliminated, the permit space may be declassified for as long as the hazards remain eliminated The employer must verify and document that the space is safe for entry and that all pre-entry measures discussed above have been taken and documented in a written certification that contains the date, location of the space, and the signature of the person providing the certification This must be made available to each employee entering the space If hazards arise within a space that has been declassified, all employees within the space must exit The employer then must reevaluate the space and determine whether it must be re-classed as a permit space or if other measures are necessary to maintain the non-permit space classification OTE: OSHA has clarified that if a valve used to close off a hazardous chemical line tied into a confined space is not an isolation valve, and therefore may leak, the space cannot be reclassified because there is still potential for a hazardous atmosphere (OSHA Interpretation Letter, 8/6/07) CS/Part 3-5

12 Confined Spaces Rulebook 4 Permits 41 Before entry into a permit space is allowed, the employer must prepare and issue an entry permit that has certain reuired components (29 CFR (f)) Verify that the written confined space entry program reuires issuance of a permit prior to permit space entry (29 CFR (e)(1)) Verify that the entry permit includes the following (29 CFR (f)): permit space to be entered; purpose of the entry; date and duration of the entry permit; names of the authorized entrants so that the attendant can uickly and accurately determine throughout the operation who is inside the permit space; OTE: Eually effective alternate methods such as rosters or tracking systems may be used names of the personnel serving as attendants; name of the current entry supervisor allowing for the signature or initials of the entry supervisor who originally authorized entry; hazards of the space to be entered; control measures that will be used to isolate the space and control or eliminate the permit space hazards before entry; OTE: Control measures can include lockout/tagout procedures, purging, or ventilation acceptable entry conditions; test results of initial and periodic monitoring conducted in the permit space where authorized entrants are working, accompanied by the names or initials of the testers and the date and time of the test; names and contact information for the rescue and emergency services, including the type of euipment to use and the number to call; communications procedures to be used by entrants and attendants to maintain contact during entry; a list of euipment that will be used or available while performing work in the permit space, such as personal protective euipment, rescue devices, alarm systems, and communication euipment; and any other pertinent safety information and special work authorizations (eg, hot-work permits) 42 Before entry is allowed the employer must document the completion of certain measures reuired in the program (29 CFR (e)(1) (e)(4)) Verify that the permit documents the following: The permit is issued to authorize entry only when the measures reuired in the written program are complete The entry supervisor signs the permit before entry begins The completed initial entry permit is made available at the time of entry to all authorized entrants by posting or other eually effective means, so that entrants can confirm that pre-entry preparations have been completed Permits are not issued for periods that exceed the time reuired to complete necessary work OTE: 29 CFR Appendix D shows examples of appropriate permits Verify that the entry permit is completed accurately and identifies the authorized entrants by name or through the use of a roster or other tracking system Interview entrants and attendants and review completed permits to determine if the permit system functions effectively, that is: the entrants and attendants understand the purpose and use of the permit form; all parts of the permits are properly completed; and problems encountered during an entry operation are noted on the permit so that appropriate revisions can be made in the permit program (29 CFR (e)(6)) CS/Part 3-6

13 43 Procedures must be in place to terminate entry permits (29 CFR (e)(5)) Determine if entry permits are terminated whenever (29 CFR (e)(5)): the task has been completed; or a condition that is not allowed under the entry permit arises in or near the permit space 5 Training and Duties Confined Spaces Rulebook 44 Canceled entry permits must be retained for at least one year and used in reviewing the confined space program (29 CFR (e)(6)) Ensure that entry permits are maintained for at least one year and are used as part of the reuired annual review of the confined space entry program (see section 7) 29 CFR (e)(6)) 51 Training must be conducted for employees who act as attendants, entrants, supervisors issuing permits, and rescue personnel (29 CFR (g)) Interview employees and review records to determine if training is provided to attendants, entrants, authorizing supervisors, and rescue personnel (29 CFR (g)(1) and (2)): before they are first assigned duties in permit space entry; before changing their assigned duties; before there is a change in permit space entry operations (including a change in procedures) about which an employee has not been previously trained; or whenever the employer has reason to believe that there are deviations from proper procedures or there are inadeuacies in the employee s knowledge or use of proper procedures Verify that employees with assigned duties for confined space entry are reuired to demonstrate proficiency before they are allowed participation in a permit space entry (29 CFR (g)(3)) Verify that the employer has certified the training records and that the records contain each employees name, the signatures and initials of the trainer, and the dates of the training (29 CFR (g)(4)) 52 The employer must ensure that authorized entrants are assigned certain duties (29 CFR (h)) Verify that authorized entrants are assigned the following duties (29 CFR (h)): know the hazards that may be faced on entry, including knowledge of the conseuences of the exposure, and modes, signs, and symptoms of hazards associated with entry; properly use assigned euipment; communicate with the attendant as necessary to enable attendant to monitor status and to alert entrants of the need to evacuate space; alert the attendant whenever a warning sign or symptom of a dangerous situation is recognized, or if a prohibited condition arises; and evacuate the space as uickly as possible if: 1) an order to evacuate is given by the entry attendant or supervisor; 2) the entrant recognizes any warning sign or symptom of exposure to a hazardous situation; 3) the entrant detects a prohibited condition; or 4) an evacuation alarm is activated 53 The employer must ensure that attendants are assigned certain duties (29 CFR (i)) Verify that attendants are assigned the following duties (29 CFR (i)): know the hazards that may be faced on entry, including knowledge of the conseuences of the exposure, and modes, signs, and symptoms of hazards associated with entry; CS/Part 3-7

14 Confined Spaces Rulebook be aware of possible behavioral effects of exposure in authorized entrants; continuously maintain an accurate count of the number of authorized entrants in the permit space and accurately identify who is inside the confined space; remain outside of the permit space during entry operations until relieved by another attendant; OTE: Attendants who permitted to enter the space as part of rescue (see paragraph 62) may do so only after they have been relieved by another attendant communicate with the entrants as necessary to monitor status and to keep alert to any need to evacuate the space; and summon rescue and other emergency services as soon as the attendant determines that entrants may need assistance to escape from the permit space (29 CFR (i)(7)) Verify that the attendant monitors activities inside and outside the permit 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 if any of the following conditions occur (29 CFR (i)(6)): a prohibited condition is detected; the authorized entrants show signs of behavioral effects of hazard exposure; a situation outside of the permit space may result in a dangerous situation for the authorized entrants working in the permit space; or the attendant cannot effectively and safely perform all duties as assigned Verify that the attendant takes the following precautions when unauthorized persons approach or enter a permit space while entry is underway (29 CFR (i)(8)): warn unauthorized persons to stay away from the permit space; advise the unauthorized persons to exit the permit space immediately if they enter the permit space; and inform the authorized entrants and entry supervisor if unauthorized persons have entered the permit space 54 The employer must ensure that the entry supervisor is assigned certain duties (29 CFR (j)) Verify that entry supervisors are assigned the following duties (29 CFR (j)): know the hazards that may be faced on entry, including the conseuences of exposure, and modes, signs, and symptoms of hazards associated with entry; know to check that all appropriate items have been completed on the entry permit prior to authorizing entry, including verifying that all tests specified by the permit have been conducted and that all procedures and euipment specified by the permit are in place; verify that rescue services are available and the means for summoning rescue is operable; terminate and cancel the permit when the entry operations are completed or if a condition outside the scope of the permit arises in or near the permit space; remove unauthorized personnel who enter or attempt to enter the permit space during entry operations; and determine, whenever responsibility for an entry is transferred and at intervals dictated by the hazards and operations performed within the space, if entry operations are consistent with the terms of the entry permit, and acceptable entry conditions are maintained CS/Part 3-8

15 Confined Spaces Rulebook 6 Rescue Operations and Euipment 61 The employer must evaluate prospective rescuer s ability to effectively respond to a rescue summons in order to designate appropriate services (29 CFR (k)(1)) Verify that the employer evaluates prospective rescuers for the following (29 CFR (k)(1)(i) and (ii)): ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified; and OTE: What will be considered timely will vary according to the specific hazards involved in each entry For example, 29 CFR , Respiratory Protection, reuires 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 proficiency with rescue-related tasks and euipment to be able to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified OTE: 29 CFR Appendix F contains examples of criteria which employers can use in evaluating prospective rescuers Verify that the employer selects a rescue team or service from those evaluated that (29 CFR (k)(1)(iii)): has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified; and is euipped for and proficient in performing the needed rescue services OTE: If the employer selects a local fire department to perform rescue services, there must be close communication with the rescue service during entry operations so that if the fire department is called away to another emergency, and therefore becomes unavailable while an entry is underway, the employer can instruct the attendant to abort the entry immediately Entry operations cannot resume until the entry supervisor verifies that rescue services are again able to respond in a timely manner (OSHA Interpretation Letter, 5/23/2008) Verify that the employer informs the selected rescue team, or service, of the hazards they may confront when called on to perform a rescue at the site and provides them with access to all permit spaces from which a rescue may be necessary so that they can develop appropriate rescue plans and practice rescue operations (29 CFR (k)(1)(iv) and (v)) 62 If the employer allows employees to enter permit spaces to perform rescue services, these employees must be provided with certain PPE, trained, and must practice their assigned duties (29 CFR (k)(2) ) If employees will be allowed to enter permit spaces to perform rescue services, verify that the following measures are taken for affected employees (29 CFR (k)(2)): Provide employees with the PPE needed to conduct permit space rescues safely and train them so they are proficient in the use of that PPE, at no cost to those employees Train employees to perform rescue duties, including training euivalent to that reuired for authorized entrants (see paragraph 52) Train employees in first-aid and CPR and ensure that at least one member of the rescue team, or service, holds a current certification in first aid and CPR Ensure that 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 63 The facility must use retrieval euipment that can be operated by attendants from outside of the confined space, unless the retrieval euipment would increase the overall risk of entry (29 CFR (k)(3)) Verify that non-entry rescue is facilitated by the use of retrieval euipment as follows (29 CFR (k)(3)): CS/Part 3-9

16 Confined Spaces Rulebook Each authorized entrant must 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 OTE 1: Wristlets may be used in lieu of the harness if the employer can demonstrate that use of a harness is not feasible or creates a hazard and the use of wristlets is the safest alternative OTE 2: OSHA has clarified that it may not be necessary for an idividual retrieval line to be provided for each authorized entrant Attaching entrants seuentially to a single retrieval line may be acceptable, as long as each entrant can be removed from the PRCS individually and the arrangement does not impede the removal of the entrants (OSHA Interpretation Letter, 2/25/2013) The other end of the retrieval line must 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 it is necessary OTE: A mechanical device must be available to retrieve personnel from vertical permit spaces more than 5 ft deep 64 Pertinent safety data sheets (SDSs) or other similar written information must be made available to the medical facility treating exposed entrants (29 CFR (k)(4)) Verify that SDS information is available to medical personnel treating injured entrants in the event of an emergency (29 CFR (k)(4)) 7 Program Review 71 The written permit-reuired confined space entry program must be reviewed (29 CFR (d)(13) (d)(14)) Determine if the program is reviewed and revised as follows (29 CFR (d)(13) (d)(14)): when the employer has reason to believe that the control and operational measures taken under the program may not adeuately protect employees (examples include entry without a permit, occurrence of a near miss condition or injury, or employee complaints concerning effectiveness) (29 CFR (d)(13)); and annually by reviewing canceled permits (29 CFR (d)(14)) OTE: A single annual review can be performed covering all entries during the previous 12-month period If no entry is performed during a 12-month period, no review is necessary Where contractors perform permit entries, determine if those entries are reviewed to determine the need for revision of procedures (GMP) CS/Part 3-10

17 COFIED SPACES PART 4: SCORESHEET SITE: DATE: 1 General Reuirements /A Complies Does not comply 11 The facility must evaluate the workplace to determine if any spaces are permitreuired confined spaces (29 CFR (c)(1) and (c)(6)) 12 Permit-reuired confined spaces must be identified by posting warning signs (or other effective methods) to inform employees of the existence and location of, and the danger posed by, the permit spaces (29 CFR (c)(2)) 13 If the employer decides that employees will not enter confined spaces, the employer must take effective measures to prevent employees from entering confined spaces (29 CFR (c)(3)) 2 Contractors /A Complies Does not comply 21 When the employer (host employer) arranges to have contractors perform work that involves permit-reuired confined space entry, the host employer must inform the contractor that the workplace contains permit spaces and that entry is allowed only via compliance with a permit space program (29 CFR (c)(8) and (c)(9)) 3 Permit Reuired Confined Space Program /A Complies Does not comply 31 An employer whose employees enter permit spaces must develop and implement a written permit space program (29 CFR (c)(4), 29 CFR (d)(1) (d)(2) and (29 CFR (l)) 32 The employer s written permit space program must include certain elements (29 CFR (d)(3) and 29 CFR (d)(6) (d)(12)) 33 The employer must provide and maintain the euipment reuired to safely enter the permit spaces, and must ensure that employees use the euipment properly (29 CFR (d)(4)) 34 The confined space entry program must include monitoring of the atmosphere in the space prior to entry to as needed to ensure safe entry conditions exist before entry is authorized, and during entry to ensure as needed safe entry conditions are maintained (29 CFR (d)(5)) 35 An employer may use an alternate program in lieu of a permit-reuired confined space program under certain conditions (29 CFR (c)(5)) 36 When using an alternate entry techniue, the employer must conduct operations according to certain specified procedures (29 CFR (c)(5)(ii)) 37 The facility can reclassify a permit space as a non-permit space under certain conditions (29 CFR (c)(7)) CS/Part 4-1

18 Confined Spaces Scoresheet 4 Permits /A Complies Does not comply 41 Before entry into a permit space is allowed, the employer must prepare and issue an entry permit that has certain reuired components (29 CFR (f)) 42 Before entry is allowed the employer must document the completion of certain measures reuired in the program (29 CFR (e)(1) (e)(4)) 43 Procedures must be in place to terminate entry permits (29 CFR (e)(5)) 44 Canceled entry permits must be retained for at least one year and used in reviewing the confined space program (29 CFR (e)(6)) 5 Training and Duties /A Complies Does not comply 51 Training must be conducted for employees who act as attendants, entrants, supervisors issuing permits, and rescue personnel (29 CFR (g)) 52 The employer must ensure that authorized entrants are assigned certain duties (29 CFR (h)) 53 The employer must ensure that attendants are assigned certain duties (29 CFR (i)) 54 The employer must ensure that the entry supervisor is assigned certain duties (29 CFR (j)) 6 Rescue Operations and Euipment /A Complies Does not comply 61 The employer must evaluate prospective rescuer s ability to effectively respond to a rescue summons in order to designate appropriate services (29 CFR (k)(1)) 62 If the employer allows employees to enter permit spaces to perform rescue services, these employees must be provided with certain PPE, trained, and must practice their assigned duties (29 CFR (k)(2) ) 63 The facility must use retrieval euipment that can be operated by attendants from outside of the confined space, unless the retrieval euipment would increase the overall risk of entry (29 CFR (k)(3)) 64 Pertinent safety data sheets (SDSs) or other similar written information must be made available to the medical facility treating exposed entrants (29 CFR (k)(4)) 7 Program Review /A Complies Does not comply 71 The written permit-reuired confined space entry program must be reviewed (29 CFR (d)(13) (d)(14)) ED OF SCORESHEET CS/Part 4-2