CONFINED SPACE ENTRY PROGRAM

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1 INTRODUCTION Purpose: OSHA promulgated the provisions of 29 CFR intending that compliance with the regulations would reduce the number of explosions, fires and illness and/or injury caused safety hazards associated with work duties conducted in confined spaces. A copy of the applicable CFR text is available at where you can retrieve by CFR citation. This Confined Space Program ( Program ) has been developed and implemented to promote a safe workplace and in compliance with the applicable statutory scheme. Review: This Program is subject to review and/or revision on an annual basis by the facility manager, Company s Safety Officer and General Manager. Additional review and/or revision may be conducted if new confined spaces and/or hazards are identified before the annual review. Enforcement: Failure, by any employee, to comply with this Program will result in immediate disciplinary action. Such action will include, but is not limited to, written warning included in personnel file, suspension (paid or unpaid) or immediate discharge from employment. The disciplinary action taken is at the sole discretion of the on-site supervisor and management of this Company. CONFINED SPACE HAZARDS The following is a non-comprehensive list hazards associated with working in a confined space: 1. Engulfment: surrounding or effective capture of a person by liquid, 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 2. Entrapment: occurs in confined space where configuration (design) allows for entrant to be trapped or asphyxiated by product because of inwardly converging walls (i.e. cone shaped tanks) or by a floor which slopes downward and tapers to a smaller cross-section 3. Entanglement: catching of a body part, clothing or other attached material in moving equipment 4. Hazardous Atmosphere: conditions which, when entrant is exposed, may cause incapacitation, impairment of self rescue tasks, acute illness, injury or death. Some conditions which result in hazardous atmosphere may include: a. Flammable gasses b. Airborne combustible dust c. Oxygen deficient (< 19.5%) or saturated (> 23.5%) 1

2 SIGNS The Company has worked diligently to identify all Permit Required Confined Spaces at this facility. These areas are identified by signs posted at the location. The signs contain the following (or similar) language: DANGER Permit Required Confined Space DO NOT ENTER TRAINING PROGRAM Applicability: This training program applies to all Company work operations where employees may be performing work duties in a confined space. Training: The training, at a minimum, will include discussion of: 1. Summary of the 29 CFR and this written program 2. Potential hazards associated with confined spaces at grain handling facilities 3. Identification of confined spaces at specific facility 4. Entry procedures for Permit Required confined space, including use of necessary PPE and completion of Entry Permit 5. General emergency response and rescue information (including contact information for outside rescue operations) Who Is Trained: Everyone who may reasonably be expected to perform job duties in confined spaces at this facility. In order to accommodate personnel who may not speak English or be proficient in the English language, the Company will: Not allow the employee to begin work activities until the employee has been provided with confined space program training that is translated into the employee s primary language Make arrangements for the employee to be trained on specific confined space entry techniques (both permit required and non-permit required) by a person identified as competent, skilled, and fluent in the employee s primary language Provide information to the employee concerning the availability of instruction on English as a second language When Is Training Conducted: Training will occur when an employee is initially hired and on an annual basis thereafter. Additional refresher training may be required for employees found to be in violation of this Program. CONTRACTOR NOTIFICATION Contractor Notification: Contractors, whose employees may be required to conduct work operations within a confined space at the Company s facilities or work-sites, including construction sites, will be informed of the hazards associated with confined spaces before the Contractor s employees being work. The Company will: 2

3 Inform the Contractor of known potential fire and explosion hazards related to the proposed work site for the contractor Inform the Contractor of the Company s safety procedures, including, but not limited to a. Hot Work Permit b. Permit Required Confined Space c. Emergency Action Plan d. Hazard Communication Have a copy of the Company Safety Procedures available on site for review by the Contractor and his/her employees during facility work hours CONFINED SPACE ENTRY PROCEDURE General: The following precautions must be taken any time an employee s job duties require entry into a confined space. 1. Prior to entry all potential hazards must be identified, evaluated and eliminated and/or controlled. The below table identifies minimum conditions that must exist before entry can occur. ITEM Oxygen Flammable Gases Acutely Toxic Substances Flammable Dusts (does not include respiratory hazard or PEL) Engulfment Hazard Hazardous Flows Hazardous Energies External/Other Hazards ACCEPABLE CONDITION 19.5% minimum 23.5% maximum No greater than 10% of the Lower Flammability Limit (LFL) Cannot exceed permissible exposure limit (PEL) for the substance as established by OSHA in Subpart Z of 29 CFR 1910 Must not reduce vision to five (5) feet or less* May not be present Secured and locked out Secured and locked out Identified and controlled appropriately ENTRY IS PROHIBITED if any of the above conditions are not met. In the event that the confined space is already occupied when the conditions are not met, the space must be immediately evacuated. In the event that unsafe conditions are identified during atmospheric testing: a. Ventilation shall be provided until the unsafe condition is eliminated and shall continue as long as there is a possibility of recurrence of the unsafe condition while space is occupied. b. If ventilation cannot eliminate a toxic or oxygen deficient condition, the proposed entrant must wear an appropriate respirator (see 29 CFR ). 2. De-energize, Lockout and Tagout, all equipment that may present a risk for the employee in the confined space 3

4 CONFINED SPACE ENTRY PROGRAM 3. Conduct testing for atmospheric conditions (oxygen, combustible particles and toxic gasses). Atmospheric testing, using appropriate manufacturer recommended procedures, must include: a. Evaluation of environment to identify any hazardous element(s) present in atmosphere; and b. Verification/re-testing of the atmosphere to confirm that atmospheric conditions remain within acceptable parameters c. In the event that entry involves movement through a stratified atmosphere, testing should take place every four (4) feet in the direction of travel and from side-to-side 4. Prepare Confined Space Entry Permit for review and signature of supervisor. Permits are to be maintained in the facilities active permit file until the entry operation is complete. Upon completion, the permit is placed in a canceled entry permit file and maintained for a minimum of three (3) years. A permit is not required when the person who is authorized to sign permits (supervisor) is present for the entire entry operation. 5. Confirm that rescue equipment is ready and available near the entry site. 6. Guard entrances with a railing barrier to protect against falls and foreign objects 7. Station an attendant outside of the confined space. The attendant must be able to communicate with the entrant by sight, sound or signal line and monitor the situation for any changes indicating a hazardous environment exists. Attendant will monitor entrant at all times, NO OTHER JOB DUTIES can be performed by the attendant until the entrant has completed their work and exited the confined space. Attendant should be trained in First Aid and rescue procedures. Top Entry: Entry from the top of any bin, vault, vat, etc. is expressly prohibited unless the following: 1. All alternatives to top entry have been exhausted (i.e. use of portable vac or opening floor sump) 2. Proposed entry and reasons for top entry have been reviewed and discussed with supervisor who approves top entry 3. Atmospheric testing (as identified in the General Procedure portion of this Program) has been conducted 4. All floor openings, gates and/or spouts that allow product to flow from confined space have been closed and locked and tagged out 5. All transfer conveyance devices, distributors, gates, etc. that transfer product into the confined space have been closed and locked and tagged out 6. Prepare Confined Space Entry Permit for review and signature of supervisor. Permits are to be maintained in the facilities active permit file until the entry operation is complete. Upon completion, the permit is placed in a canceled entry permit file and maintained for a minimum of three (3) years. A permit is not required when the person who is authorized to sign permits (supervisor) is present for the entire entry operation. 7. All entrants must be wearing a full body harness with D-ring attached to a lifeline or emergency retrieval device, or seated in an approved boatswain chair. At no time shall the entrant be lowered to a level where the entrant s body is below the highest level of the product contained in the confined space. 8. Confirm that rescue equipment is ready and available near the entry site. 9. Guard entrances with a railing barrier to protect against falls and foreign objects 10. Station an attendant outside of the confined space. The attendant must maintain continuous verbal and visual contact with the entrant at all times. Attendant must monitor the situation for any changes indicating a hazardous environment exists. Attendant will monitor entrant at all times, NO OTHER JOB DUTIES can be performed by the attendant until the entrant has completed their work and exited the confined space. Attendant should be trained in First Aid and rescue procedures. 4

5 FLAT STORAGE ENTRY PROCEDURE General: The following precautions must be taken any time an employee s job duties require entry into a flat storage structure 1. Atmospheric testing (as identified in the General Procedure portion of this Program) has been conducted 2. All transfer conveyance devices, distributors, gates, etc. that transfer product into the confined space have been de-energized and locked and tagged out 3. Entrant is equipped with lifeline or alternative means which the employer demonstrates will prevent the entrant for sinking further than waist deep into the grain, when engulfment and/or entrapment hazards exist 4. Guard entrances with a railing barrier to protect against falls and foreign objects 5. Station an attendant outside of the confined space. The attendant must maintain continuous verbal and visual contact with the entrant at all times. Attendant must monitor the situation for any changes indicating a hazardous environment exists. Attendant will monitor entrant at all times, NO OTHER JOB DUTIES can be performed by the attendant until the entrant has completed their work and exited the confined space. Attendant should be trained in First Aid and rescue procedures. PROHIBITED ACTIONS At all times, regardless of the type of confined space entered, no employee shall engage in: 1. Walking down grain (or similar practice): walking on grain to make it flow within or out from a grain storage structure 2. Moving grain: no employee is to be on moving grain at any time 3. Bridging conditions: no employee is permitted to be either underneath a bridging condition or in any location where an accumulation of grain on the sides or elsewhere could fall and engulf the employee EMERGENCY RESPONSE AND RESCUE General: There are a number of potential emergencies that may arise when working within a confined space. The following is a non-comprehensive list of potential confined space emergencies: 1. Entrant is overcome by sudden development of hazardous atmospheric condition 2. Entrant engulfed by free-flowing solid or liquid material 3. Entrant injured or incapacitated by mechanical or physical hazard or acute illness Rescue types: 1. External rescue: entrant is wearing safety harness/lifeline and is extricated without rescuers entering the confined space 2. Internal rescue: Rescuers must enter the confined space to effectuate the rescue; may occur because entrant is unable to assist in rescue efforts (i.e. incapacity) 5

6 Rescue Equipment: Appropriate Confined Space emergency equipment must be immediately available and accessible for all confined space entries. A mechanical device (e.g. retrieval hoist with accessories) must be available to retrieve personnel from vertical type confined spaces that are more than five (5) feet deep. Rescuers: The Company can choose one of two options in establishing assistance in confined space emergency rescue operations. The Company can either arrange for an outside rescue service to provide assistance in confined space emergency or create and train an in-house rescue team. The Company has elected to. IF OUTSIDE RESCUE SERVICE: The information regarding the identity and contact information for each of the outside rescue service providers is found in the table located in Appendix A4 of this Program. A copy of which is included in the facility Safety Procedure manual and posted with the Confined Space Entry Permits for review by employees requesting said permit. IF IN-HOUSE RESCUE TEAM: The Company s In-House Rescue Team contact information is found in Appendix A-5 of this Program. A copy of which is included in the facility Safety Procedure manual and posted with the Confined Space Entry Permits for review by employees requesting said permit. All members of the In-House Rescue Team have reviewed the Plana for Confined Space Emergency found in Appendix A-3 of this Program and received initial training on the following: 1. Confined Space entry procedures as applicable to all confined space entrants; 2. Basic Emergency Response Training (ERT), including; Alert and notification procedures Emergency response procedures Establishment of incident command procedure Selection, care, use of personal protective equipment (e.g. self contained breathing apparatus), and post incident critical stress 3. Use of Confined Space entry and emergency equipment, including Air monitoring devices Ventilation equipment Safety harness Retrieval lines and retrieval hoists 4. Simulated Confined Space rescues 5. First Aid/CPR Certification (all employees must complete and remain currently certified in basic First Aid and CPR Training, including instruction of blood borne pathogens) Employees remaining on the In-House Rescue Teams also attend annual refresher training, which includes practicing simulated Confined Space rescue. 6

7 APPENDICIES Appendix: Attached for reference and enhanced understanding of this Program, are the following: A-1: A-2: A-3: A-4: A-5: Sample Entry Permit Pre-Entry Planning Checklist Plan for Confined Space Emergency Sample Outside Rescue Service Information Sample In-House Rescue Team Information 7

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