Program No Introducing hazards into Non-Permit Required Confined Spaces Atmospheric Testing

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1 Space 1.0 INTRODUCTION ENVIRONMENTAL HEALTH AND SAFETY PROGRAM MANUAL As part of the Weill Cornell Medical College (WCMC) Environmental Health and Safety (EHS) Program Manual, this Space Program has been established. The Space Program promotes a safe work environment and complies with the Occupational Safety and Health Administration (OSHA) Permit-Required Space Standard (29 Code of Federal Regulations ). 2.0 TABLE OF CONTENTS Section Heading Page # 1.0 Introduction Table of Contents Objective Applicability Responsibilities Types of Space Identification and Warning Unauthorized Entry Non-Permit Required Spaces Introducing hazards into Non-Permit Required Spaces Permit-Required Space Procedure Atmospheric Testing Ventilation Training Record Retention, Availability, and Review Definitions 11 Appendix A Space and Permit-Required Space at WCMC Appendix B Space Entry Permit 1 of 12

2 Space 3.0 OBJECTIVE Many workplaces contain spaces that are considered "confined" due to configurations that hinder the activities of employees entering, working in, or exiting the spaces. OSHA defines a confined space as any space that is large enough and so configured that an employee can bodily enter and perform assigned work, has a restricted means of entry or exit, and is not designed for continuous employee occupancy. All of these criteria must be met for a space to be classified as confined. Examples of confined spaces include tanks, pits, certain tunnels, utility vaults, and boilers. In addition, there are many instances where employees who work in confined spaces face increased risk of exposure to serious hazards. In some cases, confinement poses entrapment hazards. In other cases, confined space work keeps employees closer to hazards, such as asphyxiating atmospheres or the moving parts of machinery. OSHA uses the term "permitrequired confined space" to describe those spaces that meet both the definition of confined space and pose health or safety hazards. The Space Program should be used in conjunction with other EHS safe work practices including: use of Personal Protective Equipment (PPE), safe handling of hazardous materials and isolation of energy sources (Lock-out/Tag-out). It is the objective of this Program to protect WCMC staff and outside contractors from the health and safety risks associated with working in confined spaces. 4.0 APPLICABILITY The following program applies to all WCMC employees or contractors who may encounter confined spaces during the course of their work. WCMC employees are not permitted to enter Permit-Required Spaces. College employees should follow the alternate procedures for entering Non Permit-Required Spaces on the campus. 5.0 RESPONSIBILITIES 5.1 ENVIRONMENTAL HEALTH AND SAFETY (EHS) Develop, administer and manage the Space Program. Issue and maintain Space Entry Permits. Identify, label, and document all WCMC Permit-Required Spaces. Provide training as needed for all personnel who may encounter confined spaces. Conduct assessments of confined spaces to recommend appropriate entry procedures, personal protective equipment (PPE), air monitoring, and ventilation. Review outside contractors written Space policies, training certificates, and Material Safety Data Sheets (MSDS's). Retain completed Space Permits and review annually. 5.2 ENGINEERING & MAINTENANCE Recognize confined spaces, and differentiate between Permit-Required and Non Permit-Required Spaces. 2 of 12

3 Space Enter only Non Permit-Required Spaces and follow procedures when entering confined spaces. Notify EHS when confined space entry work is scheduled to be performed by outside contractors. Provide EHS with their Contractor s Space Program and training records (7 days prior to entry) to ensure that it is consistent with the WCMC Space Program. Notify EHS of any incidents that occur in connection with any confined space entry. 5.3 DEPARTMENTS / SUPERVISORS Implement the Space Program. Request training / refresher training from EHS as needed. Notify EHS upon discovery of any potential Permit-Required Spaces. Inform EHS when confined space entry work is scheduled to be performed by outside contractors. Notify EHS of any incidents that occur in connection with any confined space entry. 5.4 CAPITAL PLANNING / PROJECT MANAGERS Implement the Space Program. Notify EHS upon discovery or construction of any potential Permit-Required Confine Spaces. Inform EHS when confined space entry work is scheduled to be performed by contractors. Notify EHS of any incidents that occur in connection with any confined space entry. 5.5 CONTRACTORS Provide EHS with their Space Program and training records (7 days prior to entry) to ensure that it is consistent with the WCMC Space Program requirements. Implement their (Contractor s) Space Program when working in any confined space at WCMC Obtain a permit from EHS prior to entering any Permit-Required Space. 6.0 TYPES OF CONFINED SPACES Many spaces on the WCMC campus can be considered "confined" due to internal configurations that hinder the activities of employees entering, working in, or exiting the spaces. OSHA defines a confined space as, any space that is large enough and so configured that an employee can bodily enter and perform assigned work, has a restricted means of entry or exit, and is not designed for continuous employee occupancy. spaces can be divided into two categories: Non Permit-Required and Permit-Required Spaces. 3 of 12

4 Space 6.1 NON PERMIT-REQUIRED CONFINED SPACES A Non Permit Required Space is: large enough for an employee to enter fully and perform assigned work; not designed for continuous occupancy by the employee; and has limited or restricted means of entry or exit. Some examples of confined spaces are: shafts, crawlspaces, air handling units, vaults, and tanks. 6.2 INTRODUCTION OF HAZARDS INTO NON PERMIT-REQUIRED CONFINED SPACES The introduction of certain hazards may change the atmospheric conditions of a non permit-required confined space and required additional entry procedures. Some specific hazards that may require alternate entry procedures are: Hotwork (welding, torch cutting, brazing) Chemicals (coatings, paints, ect.) Compressed Gasses EHS must be contacted to conduct an evaluation of a confined space when hazards are to be introduced. 6.3 PERMIT-REQUIRED CONFINED SPACES A Permit-Required Space also has one or more of the following characteristics: contains or has the potential to contain a hazardous atmosphere; contains a material with the potential to engulf someone who enters the space; has an internal configuration that might cause an entrant to be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section; and/or contains any other recognized serious safety or health hazards. Examples of Permit-Required Spaces include the acid neutralization tanks in the basement of the 1300 York Avenue complex and the S Building. Refer to Appendix A for a full list of Permit-Required Spaces at WCMC. 7.0 IDENTIFICATION AND WARNING EHS has identified, classified, and recorded the location of confined spaces at WCMC. A list of and Permit-Required Spaces is available in Appendix A and is kept on file in the EHS office. Contractors working at WCMC should be provided this manual by Project Managers, which contains a list of confined spaces at the College. It is the responsibility of contractors working at WCMC to read and ensure all work is performed in compliance with this manual and 29 CFR If a location encountered on campus appears to meet the definition of a confined space, and is not posted as such nor appear in Appendix A, contact EHS. 4 of 12

5 Space Permit-Required Spaces located inside buildings are identified and posted with appropriate signs to guard against the entry of unauthorized individuals. Where possible, Permit- Required Spaces will be secured to prevent unauthorized entry. Permit-Required Space signs at WCMC must state, Danger Space Enter by Permit Only (see Figure 7.1 below). Figure UNAUTHORIZED ENTRY Unauthorized entry into Permit-Required Spaces will be prevented using a combination of signs and placards, training, and physical barriers to bar or lock the entrance or entrance cover. WCMC employees must not enter Permit-Required Spaces under any circumstances. All entry into WCMC Permit-Required Spaces must be conducted by a properly trained contractor and coordinated with EHS. 9.0 NON PERMIT-REQUIRED CONFINED SPACE PROCEDURES All individuals who enter a non-permit required confined space should be aware of the specific hazards that are posed in the space and take the appropriate safety precautions to protect themselves INTRODUCING HAZARDS INTO NON PERMIT-REQUIRED CONFINED SPACE A variety of tasks and work activities have the potential to create additional hazards in Non Permit-Required Spaces. If additional hazards will be introduced into a space, Permit- Required Space or additional entry procedures may be required. All work that will introduce additional hazards into a confined space must first be coordinated and evaluated by EHS. This includes all hotwork and/or work involving the use of chemicals which have inhalation hazards associated with them. These work tasks may create a potentially hazardous atmosphere and necessitate Permit-Required or modified confined space procedures. EHS will conduct an assessment of the space, make recommendations for personal protective equipment, engineering controls, and conduct air monitoring for all WCMC work activities that may introduce additional hazards into confined spaces. 5 of 12

6 Space Contractors conducting work in and introducing hazards into Non Permit-Required Spaces must also have these spaces evaluated by EHS. The WCMC Project Manager or representative from the contractor should contact EHS to have the space evaluated and the entry coordinated. The contractor must the follow all entry requirements. Any required atmospheric monitoring, addition PPE, or equipment must be provided by the contractor PERMIT-REQUIRED CONFINED SPACE PROCEDURES Due to the extensive training, equipment, and personnel requirements, Permit-Required Spaces will not be entered by WCMC employees. Entries into the permit-required confined spaces at WCMC will only be conducted by authorized contractors. Contractors who are required to enter WCMC permit-required confined spaces must submit their written Space policies, training certificates, and Material Safety Data Sheets (MSDS s) to EHS at least seven days prior to the commencement of work. EHS will apprise the contractor of any hazards identified, experience with the space, and what classifies it as a permit-required confined space. EHS will coordinate entry operations with the contractor if WCMC personnel or other contractor personnel are working in or near the confined space being entered. If employees of more than one employer are working simultaneously as authorized entrants in a confined space, procedures to coordinate entry operations must be developed and implemented. Contractors entering WCMC Permit-Required Spaces will follow procedure below ENTRY SUPERVISOR / PROJECT MANAGER Identify the staff members who will enter the confined space and determine what role they will have while working in the space. Typical roles may include, but are not limited to, the following: o Authorized Entrant(s) o Authorized Attendant(s) o Rescue / Emergency Services Team Receive training in the same procedures as authorized entrants and attendant. Develop procedures prior to the commencement of confined space operations for: o Rescuing entrants from permit-required confined spaces. o Providing necessary emergency services for rescue. o Summoning rescue and emergency services. o Preventing unauthorized personnel from attempting a rescue. o PPE required for safe entry into space. Obtain a Space Entry Permit from EHS before entry into any permitrequired confined space (see Appendix B). Post the original Space Entry Permit conspicuously at the job site until the work shift and/or the job is completed. 6 of 12

7 Space Designate a lead authorized entrant if supervisor is unavailable to be present for the duration of the entry. Note: it is only acceptable for the entry supervisor to leave the job site if there is not an attendant required. Ensure entry operations remain consistent with the terms of the entry permit and that acceptable entry conditions are present. Cancel the entry authorization and terminate entry whenever acceptable entry conditions are not present. Respond to the space immediately in the event of an ordered evacuation. Verify that rescue services are available and that the means for summoning them are operable. Close the Space Entry Permit at the completion of the confined space entry. Send terminated Space Entry Permits to EHS within 24 hours AUTHORIZED ENTRANTS Be aware of the hazards that may be faced during an entry, including the signs and symptoms of an exposure to a hazard as well as an understanding of the consequences of that exposure. Maintain communication with attendant (when such staff are required) and notify the attendant in the event the entrants initiate evacuation. Use appropriate PPE as designated by the entry supervisor. When respiratory protection is required; the entrant must have evidence of current fit testing and training. Any external barriers needed to protect entrants from external hazards must be explained and used. Exit the space when any of the following conditions arise: o The attendant orders an evacuation. o An automatic alarm (e.g., gas meter, fire alarm) sounds. o A warning sign or symptom of exposure to a dangerous situation is recognized AUTHORIZED ATTENDANT Maintain an accurate count of all persons in the space. Recognize hazards that entrants may face in the space including information on the mode, signs or symptoms and consequences of exposure. Receive training as an authorized entrant. Train and demonstrate proficiency with the evacuation equipment. Monitor activities inside and outside the permit space to determine if it is safe for entrants to remain in the space. Maintain an effective and continuous communication with the authorized entrants. This may range from voice to radio communication. Other means may be used as deemed appropriate and effective by the Entry Supervisor. Will only monitor one permit-required confined space entry at a time. Exceptions to this rule must be approved by EHS prior to the entry. Take the following actions when an unauthorized person approaches or enters a permit-required confined space while entry is underway: 7 of 12

8 Space o Warn the unauthorized person to exit immediately if they have entered the permit space o Inform the authorized entrants and the designated entry supervisor if an unauthorized person entered the permitted spaces. The attendant may also contact the Security Department to request immediate assistance from a Security Officer. Order immediate evacuation of entrants from permitted spaces when any of the following conditions arise: o A condition is present which is not permitted in the entry permit. o Behavioral effects that demonstrate a hazard exposure are observed. o A situation outside the space is present that could endanger the entrants. o An uncontrolled hazard is present within the permit space. o The attendant must leave the workstation. Will NOT enter the space to rescue entrants. Attendant shall not enter the space under any circumstances. In an emergency situation the attendant can use non-entry rescue methods. In case of an emergency the attendant should summon rescue services RESCUE / EMERGENCY SERVICES TEAM Non-Entry Rescue shall be performed by authorized attendants in the event of an emergency. Arrangements must be made for a rescue / emergency services team to be on standby during all permit-required confined space entries. Rescue / emergency services team must fulfill all of the requirements set forth in 29 CFR ATMOSPHERIC TESTING Atmospheric testing is required to evaluate the hazards of permit-required confined space and to verify that acceptable entry conditions are present. All atmospheric evaluations will be conducted by the contractor with equipment of sufficient sensitivity and specificity to identify and evaluate any hazardous atmospheres that may exist or arise. The internal atmosphere will be tested continuously during permit-required confined space entry, with a calibrated direct-reading instrument for the following conditions in the order given: Oxygen content (19.5% %) Flammable gases and vapors (<10%) Potential toxic air contaminants (if applicable follow OSHA PEL s) Airborne combustible dusts (if applicable follow OSHA PEL s) 12.1 TESTING PROCEDURE All atmospheric testing for analysis of confined spaces shall follow these guidelines: Test atmosphere with the opening cover on if possible or slightly open to entry to allow sampling. Sample at the face of the opening and at different levels within the space. 8 of 12

9 Space Sample time should be 2 minutes at each level for an accurate read. If meter shows above actions levels, do not enter. Allow the meter to clear in clean air and re-sample. If the meter reaches levels again, review the space, implement controls and retest. Continuous monitoring must be conducted in the space for the duration of the permit entry. Readings should be recorded every 15 minutes on the entry permit. Monitoring for hazardous vapors, dusts, mists and fumes may be necessary to determine safe exposure levels and the selection of personal protective equipment. The confined space meters do not detect substance specific hazards from processes or operations VENTILATION Forced air mechanical ventilation shall be used to control atmospheric hazards within a confined space. Caution: Forced air ventilation shall only be used to control a hazard; use of ventilation does not constitute elimination of hazard. Select the blower based on the volume of the space, number of elbows in the flex hose and the length of hose and not just on the CFM on the fan. Blower must be capable of maintaining a least 20 air changes per hour for a ventilation rate. Purge the space for at least 10 minutes prior to entry. Longer purge times may be necessary for smaller blowers or larger spaces. The forced air ventilation shall be directed to ventilate the immediate areas where an employee is or will be present within the space and shall continue until all employees have left the space. The air supply for the forced air ventilation shall be from a clean source and may not increase the hazards in the space. Place supply air hose near area of work and never lower than 25% of the total height of the space. Supply and local exhaust ventilation is necessary for hotwork in confined spaces. Locate blower away from car exhaust or other contaminant sources TRAINING 14.1 CONFINED SPACE AWARENESS TRAINING EHS will provide confined space training at the awareness level to WCMC employees who may encounter confined spaces during their normal duties. space awareness training must be attended by supervisors who have employees that enter spaces, supervisors that have confined spaces in their work areas, and employees who hire contractor's that will be entering WCMC spaces. Refresher training will be provided annually for employees. 9 of 12

10 Space EHS will only provide training at the awareness level for WCMC employees as College employees are not permitted to enter permit-required confined spaces REQUIRED CONFINED SPACE TRAINING FOR CONTRACTOR Contractors must provide appropriate training for all employees and roles associated with permit-required confined spaces at WCMC. Training records must be provided to WCMC EHS for review. In addition, contractors who are required to monitor the atmosphere in a confined space must be trained on the use of the monitoring equipment. Proof of this training will be provided to EHS RECORD RETENTION, AVAILABILTY, AND REVIEW 15.1 RECORD KEEPING All records with respect to entry and work in a confined space are retained for no less than: 1 year if no incident or unplanned event occurred during the entry; or 2 years if an incident or unplanned event occurred during the entry PROGRAM REVIEW EHS will review permits on a yearly basis and make revisions to the program as necessary TRAINING RECORDS 16.0 DEFINITIONS Contractor training documents and confined space programs will be kept on file for one year from the date of entry completion. Acceptable Entry Conditions: The conditions that must exist in a permit-required confined space to allow entry and to ensure that employees involved with a permit-required 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 authorized by the employer to enter a permit-required confined space. space: A space defined by the concurrent existence of all of the following conditions: Large enough and so configured that an employee can bodily enter and perform assigned work. Has limited or restricted means for entry or exit. Is not designed for continuous employee occupancy. 10 of 12

11 Space Dangerous Air Contamination: An atmosphere capable of causing death, injury, acute illness, or disablement due to the presence of flammable, explosive, toxic, or incapacitating substances. Enclosed space: Spaces that do not meet the definition of a confined space, but may require precautionary measures upon entering. Examples of enclosed spaces are crawl spaces and service tunnels with existing general ventilation. Emergency: Any occurrence (including any failure of hazard control or monitoring equipment) or event internal or external to the permit space that could endanger entrants. Engulfment: The surrounding and effective capture of a person by a liquid or finely divided (fluidic) 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 an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant's body breaks the plane of an opening into the space. Entry Permit: The written or printed document that is provided by the employer to allow and control entry into a permit space. A permit (Attachment B) must be completely filled out by EHS prior to entering the space. Employees entering confined spaces must have signature approval from their supervisor on the confined space entry permit prior to entry. No permit shall be valid for more than 24 hours after the time of issue by the supervisor. Entry Supervisor: The person (such as the employer, foreman, or crew chief) responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required by this section. NOTE: An entry supervisor also may serve as an attendant or as an authorized entrant, as long as that person is trained and equipped as required by this section for each role he or she fills. Also, the duties of entry supervisor may be passed from one individual to another during the course of an entry operation. Hazardous Atmosphere: An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a permitrequired confined space), injury, or acute illness from one or more of the following causes: Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent Flammable gas, vapor, or mist in excess of 10 percent 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 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 CFR1910 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, or 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. 11 of 12

12 Space Introduced Hazard Non Permit-Required Space: A space that meets all traditional definitions of a confined space but has an introduced hazard through work. Hotwork or introducing chemicals into a space will cause a Non Permit Required Space into a hazardous space. Ventilation and Atmospheric monitoring must be conducted to mitigate any hazardous atmosphere before the space can be entered. Immediately dangerous to life or health (IDLH): Any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual's ability to escape unaided from a permit-required confined space. Non-permit confined space: A confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm. Permit-Required Space: 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 Contains any other recognized serious safety or health hazard 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 that is 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 equipment (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 hazards that may confront entrants of a permit space are identified and evaluated. Testing includes specifying the tests that are to be performed in the permit space. NOTE: Testing enables employers both to devise and implement adequate control measures for the protection of authorized entrants and to determine if acceptable entry conditions are present immediately prior to, and during, entry. 12 of 12

13 Space APPENDIX A Space and Permit-Required Space at WCMC Location Type Hazard Description 1300 York A00003 Mechanical Equipment Steam Lines / extreme temperature A00017 Mechanical Equipment Open elevated area where piping runs A00018 Mechanical Equipment Open elevated area where piping runs A00019 Mechanical Equipment Open elevated area where piping runs A00020 Mechanical Equipment Open elevated area where piping runs A00022 Mechanical Equipment Open elevated area where piping runs A0034 Mechanical Equipment Acid neutralization tank with access Permit Required panel and pit > 4' in depth A0034 Mechanical Equipment Air Handler Unit A0034 Mechanical Equipment Ejector Pit Permit Required A117 Mechanical Shaft Limited egress / low head clearance A420 Research / Non classified Open shaft with access door containing Laboratory steam risers Harkness Roof Domestic Water Tank Permit Required Harkness Roof Cooling Towers B00003 Mechanical Equipment Ejector Pit Permit Required C Roof Cooling Tower C00001 Mechanical Equipment Open elevated area where piping runs C00002 Mechanical Equipment Open elevated area where piping runs C00006 Mechanical Equipment Open elevated area where piping runs C099B Library Storage Pit with ladder (Library Stacks adjacent to 2S elevator) D00001 Mechanical Equipment Open elevated area where piping runs D00002 Mechanical Equipment Open elevated area where piping runs D0003 Mechanical Equipment Steam Lines / extreme temperature D0016 Mechanical Equipment Acid neutralization tank removable top Permit Required E00001 Mechanical Equipment Open elevated area where piping runs E00002 Mechanical Equipment Open elevated area where piping runs Appendix B

14 Space Location Type Hazard Description 1300 York E00003 Mechanical Equipment Open elevated area where piping runs LC Roof Cooling Tower LC1002 Mechanical Equipment Air Handler Unit LC298D Shaft with platform Limited egress LC298E Shaft with platform Limited egress LC398D Shaft with platform Limited egress LC398E Shaft with platform Limited egress LC498C Shaft with platform Limited egress LC498D Shaft with platform Limited egress LC598C Shaft with platform Limited egress LC598D Shaft with platform Limited egress LC698E Shaft with platform Limited egress LC798C Shaft with platform Limited egress LC798D Shaft with platform Limited egress LC798E Shaft with platform Limited egress LC898D Shaft with platform Limited egress LC898E Shaft with platform Limited egress LC898F Shaft with platform Limited egress LC998C Shaft with platform Limited egress LC998D Shaft with platform Limited egress LC998E Shaft with platform Limited egress LC998F Shaft with platform Limited egress 1305 York Y00004 Mechanical Equipment Oil Tank Permit Required Y00098C Mechanical Equipment Sump pits Permit Required (roof) Y0098C Mechanical Equipment Air Handing Units Y1498B Mechanical Equipment Air Handing Units Y1598A Mechanical Equipment Air Handing Units Y15 Roof Cooling Tower Y15 Roof Cooling Tower S Building S1100 Mechanical Equipment Air Handler Unit S1100 Mechanical Equipment Domestic Water Tank Permit Required (roof) S1100 Mechanical Equipment Cooling Tower (roof) S009 Mechanical Equipment Acid neutralization tank Permit Required S009 Mechanical Equipment 2 Sump pits Permit Required 2 of 12

15 Space Location Type Hazard Description Roof Domestic Water Tanks Permit Required SI Building S055 Mechanical Equipment Ejector Pit Permit Required S320 Olin Hall OH016B Mechanical Equipment Air Handler Unit Mechanical Equipment Sewer pump pit Ejector pump pit Permit Required Roof Domestic Water Tank Permit Required Lasdon House LH06 Mechanical Equipment Ejector Pit LH1600 Mechanical Equipment Air Handler Unit Roof Cooling towers Roosevelt Island Residence RI001 Mechanical Equipment Pit housing common vacuum pipe for trash compactors running through multiple buildings Rolls Royce Building RR098H Storage Fuel Oil Tank Permit Required RR098D Wet Plumbing Acid Neutralization Tank Permit Required RR098D Wet Plumbing Acid Neutralization Tank Permit Required RR098D Wet Plumbing Ejector Pit Permit Required RR698 Mechanical Equipment Air Handler Unit RR698 Mechanical Equipment Air Handler Unit RR698 Mechanical Equipment Air Handler Unit RR698 Mechanical Equipment Air Handler Unit Roof Cooling Tower Roof Cooling Tower 3 of 12

16 Space APPENDIX B Space Entry Permit (Refer to next page) 4 of 12

17 ENVIRONMENTAL HEALTH AND SAFETY CONFINED SPACE ENTRY PERMIT GENERAL INFORMATION Location of Space (Bldg. and Rm): Type (i.e. MER, Tunnel): Duration of Permit: Date: To Time: To Purpose of Entry: PERMIT SPACE HAZARDS (Check Yes or No) Type of Hazard Yes No Oxygen deficiency (>19.5%) Oxygen enrichment (<23.5%) Flammable gases or vapors (<10% of LEL) Airborne combustible dust (meets or exceeds LEL) Toxic gases or vapors (greater than PEL) Mechanical hazards Electrical shock Materials harmful to skin Other (please list): EQUIPMENT REQUIRED FOR ENTRY AND WORK (Specify as required) Personal Protective Equipment: Respiratory Protection: Atmospheric Testing / Monitoring: Engulfment Communication: Rescue Equipment: AUTHORIZED ENTRANTS (List by name or attach roster) Name: Signature: Date: Name: Signature: Date: Name: Signature: Date: AUTHORIZED ATTENDANTS (List by name or attach roster) Name: Signature: Date: Name: Signature: Date: Name: Signature: Date: August 2011 T:\Documentation\EHS-Manual\7.3Space.doc

18 ENVIRONMENTAL HEALTH AND SAFETY COMMUNICATION PROCEDURES Describe the communication procedures to be used by entrants and attendants. PREARATION FOR ENTRY Check after steps have been completed. Notified affected departments of service interruption. Performed the following Isolation methods: Blank/blind Purge/clean Inert Lock-out/Tag-out Ventilate Atmospheric Barriers Other (please describe): Personal Awareness: Pre-entry briefing on specific hazards and control methods Notify contractors of permit and hazard conditions Other (Please describe): Additional permits required and / or attached: Hot Work Line breaking Other (Please list): TESTING RECORD Acceptable Conditions Time Oxygen-min >19.5% Oxygen-max <23.5% Flammability <10% LEF/LFL H 2 S <10 PPM Toxic (specify) CI 2 <0.5 PPM CO <35 PPM SO 2 <2 PPM Heat F 0 / C 0 Other Result Result Result Result Result Result AUTHORIZATION BY ENTRY SUPERVISOR I certify that all required precautions have been taken and necessary equipment is provided for safe entry and work in this space. Print Name Signature Date/Time August 2011 T:\Documentation\EHS-Manual\7.3Space.doc