Working in Confined Spaces

Page #: 1 of 27 Last Reviewed/Update Date: Working in Confined Spaces 1. Purpose/Background Periodically, confined work spaces must be entered for inspection, cleaning, or repair. Lack of oxygen, infiltration of toxic gases and machinery entrapment while working in these spaces can results in fatalities and serious injuries. Approximately 65 deaths occur annually including 60% of intended rescuers because confined space procedures have not been well established. Permit Required Confined Spaces (PRCSs) require specific evaluation of the hazards in and around the space and the work to be done within, and specification of the means to control or eliminate those hazards. OSHA regulation in 29 CFR 1910.146, describes requirements for practices and procedures for work in permit-required confined spaces, in general industry settings. This regulation as well as nonregulatory standards form the basis for this SOP. 2. Scope This Standard Operating Procedure describes the safety requirements necessary to enter and work in confined spaces such as boilers, manholes and vessels. 3. Safety Guidelines 3.1 Permit-required confined spaces shall be entered only after required safeguards have been taken and an approved permit issued in accordance with this guidance. 3.2 Only trained and authorized personnel shall be allowed to enter, attend to or supervise entry into permit required confined spaces. 3.3 Employee training will include regulatory requirements, MIT procedures, and tools to recognize work areas that may be or are, confined spaces. Any work planned in a confined space that is potentially a permit-required confined space requires notification to a Supervisor or EHS prior to commencement of the work. 4. Responsibilities 4.1 Department of Facilities Shall co-ordinate permit required confined space entries and shall: Ensure that attendants, entrants, and entry supervisors are trained and authorized prior to allowing any entry into a PRCS confined space entry work The required training as conducted by EHS will address all specific principals, methods, and techniques required to perform permit-required confined space work in accordance with MIT and OSHA requirements. This training will include: regulatory requirements, use of permits, confined space classification and hazard analysis, internal procedures for preparing for entry, emergency rescue, and air monitoring instrumentation. Evaluate the MIT campus to identify permit required confined spaces. If any are present, exposed employees shall be informed by posting danger signs or by any other equally effective means of the existence and location of and the danger posed by the permit spaces. Where applicable, a sign reading: DANGER -- PERMIT REQUIRED CONFINED SPACE -- DO NOT ENTER or using similar language would satisfy the OSHA requirements. Provide, maintain and keep in calibration, equipment used for entering confined spaces including; harnesses, ropes, hoisting systems, retrieval equipment, fans and ventilators,

Page #: 2 of 27 Last Reviewed/Update Date: atmospheric monitoring instrumentation, communication equipment, lighting equipment, equipment required for safe ingress and egress by authorized entrants as well as emergency respiratory equipment. Maintain completed and closed out Confined Space Entry Permits for a period of at least one (1) year and in conjunction with EHS, formally review the program effectiveness at least annually In conjunction with EHS Office, provide support in periodic revision of the inventory of confined spaces. Co-ordinate any outside contractor confined space and permit required confined space entries. All facility zone managers keep recent inventories of the confined spaces and permit required confined spaces in their zone. 4.2 Authorized Entrants An employee who is authorized by the employer to enter a permit space. Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure; Properly use equipment as required by paragraph Communicate with the attendant as necessary to enable the attendant to monitor entrant status and to enable the attendant to alert entrants of the need to evacuate the space Alert attendant whenever the entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or prohibited condition. Entrant must exit the confined space if he/she recognizes any warning sign or symptom of exposure to a dangerous situation, prohibited condition, when instructed by entry supervisor or attendant, or when evacuation alarm is sounded. 4.3 Entry Attendants An individual stationed outside one or more permit spaces who monitors the authorized entrants and who perform all attendant s duties assigned in the employer permit space. Knows the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure Is aware of possible behavioral effects of hazard exposure in authorized entrants. Before entry, notify operations of the entry, state the following information: o Exact location of confined space entry o Time of entry o Names of authorized attendants and entrants o Approximate entry duration Re-check and verify communications with the operations center if conditions change or if the anticipated entry duration changes. Notify the operations center when confined space work has been completed. Remain outside the space during entry operations at all times or until relieved by another attendant. Activities that may interfere with attendant duties shall not be performed. Continuously maintains an accurate count of authorized entrants in the permit space and ensures that the means used to identify authorized entrants accurately identifies who is in the permit space. Continuously monitor hazards both inside and outside the space. Test the atmosphere using a properly calibrated four-gas meter and ensure that the following conditions are met; o Oxygen (O 2 ) not less than 19.5%, and not greater than 23.5%; o Combustible Gasses (LEL) not greater than 10% of the LEL; o Hydrogen Sulfide (H2S) not greater than 10 ppm;

Page #: 3 of 27 Last Reviewed/Update Date: o Carbon Monoxide (CO) greater than 35 ppm. o Ensure that air contaminant levels are below their permissible exposure limits if applicable. The spaces shall be retested prior to allowing re-entry under the following circumstances: o The space has been temporarily closed o After breaks, or anytime after the space has been unoccupied o If new work must occur that has not been addressed in the permit. The space must then be vacated and a new permit issued to address the new work. Maintain communication with the entrants to be aware of any problems, which may occur. Order the entrant(s) to evacuate immediately if prohibited conditions exist. An attendant may monitor more than one permit space. The use of one attendant for more than one space shall not compromise the safety of any entrant in all the spaces being monitored by the attendant. Summon rescue and other emergency services as soon as the attendant determines that authorized entrants may need assistance to escape from the PRCS. 4.4 Entry Supervisors Entry supervisor means 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 is required by this section. Ensure that all personnel involved in the work are properly trained in accordance to 29 CFR 1910.146 and physically fit to perform the required tasks Inform entrants and attendants of the location of the spaces, the potential hazards associated with the respective spaces, and the requirement that only authorized, trained personnel may enter the spaces using the procedures outlined in this program Ensure that atmospheric and or physical hazards in the permit space have been eliminated or controlled by acceptable means. Ensure that the entry permit form is properly completed and that all pre-entry requirements of the permit have been met prior to endorsing the permit. Ensure that entry equipment, personal protective equipment, general work equipment and air monitoring equipment is maintained in working order according to manufacturer s specifications. Determine and provide additional entry or safety equipment if needed. Verify that the means for contacting the operations center are operable. Verify that entry operations remain consistent with the procedures outlined in the confined space program and that acceptable entry conditions are maintained. Ensure that appropriate measures are followed for Permit entry operations and cancel the permit once the authorized work has been completed. Maintain and review canceled permits for at least one year as part of the annual program review Identify, labeling and reporting new spaces to supervisor, zone manager, and EHS office. Terminates entries and cancels permits when prohibited conditions arise in or near the permit space. Verify that rescue services are available and can be summoned 4.5 EHS Office

Page #: 4 of 27 Last Reviewed/Update Date: Training for individuals participating in permit required confined spaces including entrants, attendants, testers, and entry supervisors. This training will include: regulatory requirements, development and use of permits, confined space classification and hazard analysis, internal procedures for preparing for entry, emergency rescue, and air monitoring instrumentation Maintain a current list of permit required confined spaces located on the MIT campus. Conduct all required communications with Cambridge Fire Department (CFD) with regard to entry rescue practice for representative spaces. Annual practice is required where the rescue service has not demonstrated rescue in similar spaces within the previous 12 months. Evaluating the overall effectiveness of the program and SOP annually through a formal review 4.6 Hazard Evaluation Measures Air monitoring will be performed before entry into permit required confined spaces to evaluate the potential for atmospheric hazards and to determine that acceptable entry conditions exist. The atmosphere will be tested to determine that the acceptable entry conditions are present. Also, the atmosphere will be tested to determine whether there is a dangerous atmosphere due to the presence of air contaminants, and/or oxygen deficiency or enrichment. Testing will be performed by properly trained workers who have successfully completed training. The minimum requirements that shall be evaluated are oxygen, combustible gasses (LEL), carbon monoxide, hydrogen sulfide and temperature. Testing will also be performed for additional air contaminants when required. 4.6.1 Atmospheric testing procedure: Air monitoring will be conducted by using a calibrated, direct reading four-gas meter and a thermometer. The meter shall be calibrated in accordance with the manufacturers recommended procedures. At the MIT Central Utilities Plant the calibration log is on file at the I & C Department. The low and high alarm values are detailed below, and on the permit. - Oxygen (O 2 ) less than 19.5%, and greater than 23.5% - Combustible Gasses (LEL) greater than 10% - Hydrogen Sulfide (H 2 S) greater than 10 ppm - Carbon Monoxide (CO) greater than 25 ppm - Air Temperature less than 130 o F when applicable. Atmospheric testing shall be performed before entry. All five conditions must be simultaneously met for acceptable entry conditions. Testing must be performed in the following order. 1. Oxygen content must be checked first, with the results indicating greater than 19.5% and less than 23.5% Note: Oxygen must be measured prior to checking for combustible gas content, because the combustible gas sensor requires the proper oxygen levels to accurately measure the combustibles. 2. Flammable/combustible vapor/gas levels must be less then 10% of LEL. 3. Toxic Gases such as carbon dioxide (CO) and hydrogen sulfide (H 2 S) levels are then checked. The results shall indicate hydrogen sulfide concentrations less than 10 ppm and carbon monoxide concentrations less than 25 ppm.

Page #: 5 of 27 Last Reviewed/Update Date: Note: If it is suspected that additional toxic atmosphere sampling may be necessary, the EH&S office must be consulted for guidance. 4. Air temperature shall then be checked last. The temperature must be less than 130 o F, when applicable. When the pre-entry testing shows there is no hazardous air contamination and/or oxygen deficiency or enrichment within the space, and there is no reason to believe that any is likely to develop, entry and work within a confined space may proceed. Any employee who enters the space, or that employee s authorized representative, shall be provided an opportunity to observe the pre-entry testing and review the testing log If a non-routine condition is suspected a representative from the EH&S office shall be consulted for guidance prior to entry. 4.6.2. Monitoring Representative Areas It is essential that the atmosphere in a permit required confined space is tested in a number of representative areas throughout the space. This is because gases and vapors may accumulate in different areas of the space depending on their vapor density. For example, methane is lighter than air and will usually be found in higher concentrations at the top of the confined space. Hydrogen sulfide is heavier than air and will tend to collect at the bottom of the space. Carbon monoxide has a relative gas density of.96 (Air = 1) which indicates that it is slightly lighter than air and has a tendency to rise. 4.6.3. Continuous air monitoring Continuous air monitoring in permit required confined spaces is required due to the potential for changing atmospheric conditions. This requirement is met by using the fourgas meter in continuous sampling mode under one of the following methods: - Place monitor inside with the worker - Place the monitor inside, set up the remote alarm outside with the attendant - Place the remote sampling tube inside with the worker and keep the monitor and pump outside with attendant. If at any point, unacceptable levels arise throughout the duration of entry, immediate evacuation of the space is necessary. Prior to re-entry, an investigation as to the cause of the unacceptable condition must be undertaken and prior to re-entry the cause must be established. The entry supervisor must then determine if additional controls must or can be implemented prior to re-entry. The space must be re-tested and a determination must be made that it is safe to re-enter. All air-monitoring results must be documented on the entry permit. For permit required confined spaces, the attendant will document with their name and record the time of initial monitoring on the entry permit. If entrants exit the space for breaks or other interruptions of work, the space must be re-tested prior to re-entry, and documented by the attendant on the entry permit with the time and their name. The permit must be posted at the entrance to the PRCS. All entrants must review the conditions prior to entry.

Page #: 6 of 27 Last Reviewed/Update Date: 5. General Procedures 5.1 Training Entrants / Attendants / Entry Supervisors All individuals potentially participating in PRCS operations shall be informed by the entry supervisor of the locations of the spaces, the potential hazards associated with the respective spaces, and the requirement that only authorized and trained personnel may enter the spaces using the procedures outlined in this program. All employees who may enter confined spaces (entrants) or who may be required to perform the duties of an entry attendant or entry supervisor shall receive training so that they acquire and demonstrate the knowledge, understanding and skills necessary to perform each of the specific duties outlined in this program Entry supervisors for permit required confined spaces have received instruction in completing and canceling the entry permit. In addition, personnel responsible for conducting atmospheric testing (i.e., authorized attendants or entrants) are trained in the proper calibration of the monitoring equipment he/she will use. Local department supervisors shall retain records for their employees for a period of 3 years. Employee training records will contain the employee s name, the trainer s signature, the date of training. This information will be maintained in the EHS Office training data base. All potential entrants must receive initial training prior to performing duties which require entry into a PRCS, or which require employees to perform the duties of an entry attendant or entry supervisor. Additionally, whenever a procedure is modified, confined space duties change or a review of the procedure identifies program deviations or inadequacies, all affected employees will be informed of any changes which will impact their duties as covered under this program. The training will include: all specific principals, methods, and techniques required to perform permit-required confined space work in accordance with MIT requirements, OSHA regulatory requirements, use of permits, use of PPE, confined space classification and hazard analysis, internal procedures for preparing for entry, emergency rescue, and air monitoring instrumentation Specific knowledge on how the permit is to be completed. The permit developed for use by MIT EHS can be found on the S drive of the EHS server: S: Confined Space\Permit template Rev7b.doc. This permit provides for specific steps to set requirements for each entry, based on hazard analysis, and verification of the requirements prior to entry. All areas of the permit should be read and completed. Procedures for non-entry self rescue as well as non-entry rescue, and emergency notification procedures. 5.2 Confined Space Entry Permits Prior to the entry into a PRCS, the hazards of the space and work to be performed shall be evaluated and a corresponding permit issued (Appendix A). Individuals participating in the entry will diligently complete all areas of the permit and jointly review the known or anticipated hazards associated with the proposed entry. Using best judgment, based on training and full knowledge of the work and intended work space, they should establish requirements

Page #: 7 of 27 Last Reviewed/Update Date: regarding the respective hazards. Although the entry supervisor has the final authorizing sign off, each participating individual shall personally review and check the adequacy of the proposed precautions. 5.2.1 Each entrant, attendant, and supervisor shall agree that the space has been prepared as indicated and are satisfied that all of the necessary safety precautions have been implemented before signing off on the permit. This is intended as a double check of the requirements and conditions in and around the space. Additionally, the entrant may request additional testing that is applicable to the confined space 5.2.2 Authorization for Entry: In this section, the entry / safety supervisor certifies that the required precautions have been taken and authorizes work to proceed. The completed permit must be posted at the entrance to the confined space. The attendant shall monitor all aspects of the entry and maintain communications with the entrant as described on the permit. If the conditions in the space change that create an unexpected hazard, increase a hazard or at the request of the entrant, the work must be stopped and the entrants shall exit the space until the new conditions can be evaluated. Any problems or unusual situations must be noted on the entry permit form. 6.2.3 Conclusion of Entry: In this section, at the completion of the confined space entry work, the entry supervisor signs off with the date and time that the permit has been canceled and the entry concluded. The permit must be filed with the Department of Facilities. 5.3 Confined Space Rescue and Emergency Services With any confined space work, hazards may arise very quickly or unexpectedly that the authorized entrants would be unable to escape from the space without assistance. In some cases, it may be possible for attendants to use extraction or rescue retrieval equipment for a non-entry rescue. However, in other cases, it may be necessary for a professional to enter the space to rescue the entrant(s). The Cambridge Fire Department has been designated as the primary rescuers service for MIT. Prior to entry, the supervisor must ensure that The CFD is available in the event they must be summoned to a rescue. If a rescue is needed inside a confined space, immediately contact MIT operations (100). Cambridge Fire Department shall be allowed access to all permit spaces from which rescue may be necessary so that the CFD can develop appropriate rescue plans and practice rescue operations. The CFD shall be notified of the hazards they may confront when called on to perform a rescue. Non-entry Rescue The following procedures will only be used if the retrieval equipment does not increase the overall risk of entry or egress. To facilitate non-entry rescue, authorized entrants shall use a full body harness with a retrieval line attached at the center of the entrants back in the dorsal area. Wristlets may be used in lieu of the full body harness if the use of full body harness is infeasible or creates a greater hazard.

Page #: 8 of 27 Last Reviewed/Update Date: The other end of the retrieval line will be attached to a mechanical lifting device (approved for this use) or fixed point outside of the permit space in such a manner that rescue can begin as soon as the attendant becomes aware that rescue is necessary. A rescue retrieval device must be deployed for non-entry rescue when personnel enter into vertical confined spaces more than 5 feet deep unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. The device when used must be deployed properly prior to the entry. Rescue retrieval devices should not be used in the following circumstances: o A horizontal entry is required o There are no safe or stable surfaces to set up the retrieval system o Entries are too large for tripods and other suitable retrieval devices have been evaluated. o The passageway has obstacles or is configured in such a way that the retrieval line could be entangled. o Protruding objects or dangerous obstacles are present, risking entanglement of retrieval line. Self Rescue The entrant upon detecting a hazardous situation removes himself from the confined space by available means such as ladder or with the aid of the attendant and the deployed retrieval device. This requires that the ladders and / or retrieval devices be in place while the space is occupied. Entry Rescue If the attendant determines that the entrant requires immediate emergency evacuation by entry into the space, they shall call the operations center at 3-1500 to immediately notify of the situation, including location, conditions, and means of access to the areas. Cambridge Fire Department shall in turn be notified of the particulars of emergency and the need for emergency rescue services. MSDS - If an injured entrant is exposed to a substance for which a Material Safety Data Sheet or other similar written information is required to be kept at MIT, that MSDS or written information shall be made available to the fire department and the medical facility treating the exposed entrant. Training MIT employees who may conduct non-entry rescue operations shall be trained in the use and limitations of the rescue retrieval device 5.4 Outside Contractors Outside contractors are responsible for their personnel and as a minimum must comply with the OSHA regulation on Permit-Required Confined Spaces, 29 CFR 1910.146. Requirements include, but are not limited to: - Provide required safety / retrieval equipment, PPE, air monitoring and calibration equipment; - Ensure that personnel are trained in accordance with requirements of 29 CFR 1910.146; - Ensure the communication of hazards to his/her employees and sub-contractors for their personnel; - Co-ordinate entry operations when MIT personnel are working near or in the same spaces; - Inform MIT of their permit required confined space program and procedures; - Debrief with the MIT contact person regarding the procedures and any hazards encountered.

Page #: 9 of 27 Last Reviewed/Update Date: Departments contracting outside services to perform confined space entries must provide the contractor with documentation of the known or potential hazards, and history associated with each space to be entered. However it is the contractor s responsibility to determine all hazards associated with a specific confined space prior to entry. 5.5 Alternate Procedures In accordance with 29 CFR 1910.146 (c) (5) alternate procedures for entering permit spaces may be used. In such instances the requirements for permits, continuous atmospheric monitoring, attendants, entry supervisors and rescue services do not need to be followed. It must be demonstrated that the only hazard posed by the permit space is an actual or potential hazardous atmosphere and that the space can be made safe by the use of continuous forced air ventilation only. MIT will develop monitoring and inspection data for each space for which alternate entry procedures will be used. Any conditions making it unsafe to remove an entrance cover shall be eliminated before the cover is removed. The openings shall be promptly guarded to prevent an accidental fall through and to protect employees working in the space from foreign objects. Prior to entering the space, the internal atmosphere shall be tested for oxygen content, flammable gases and vapors, potential toxic air contaminants and temperature. Employees may not enter the space until the forced air ventilation has made the space safe for entry as demonstrated by compliance with the provisions of the MIT acceptable for entry air monitoring levels found at Section 4.6.1. The exhaust discharge of contaminants from the space must not endanger employees in other work areas. The air supply for the forced air ventilation shall be from a clean source and shall be directed as to ventilate the area where the employee will be present. The atmosphere shall be continuously tested to ensure there is no accumulation of a hazardous atmosphere. If a hazardous atmosphere is detected the entrants shall exit the space, the space shall be evaluated and measures taken to protect employees from the hazardous atmosphere prior to re-entry Entry under this procedure is not permitted if the hazards in the space quickly increase if the ventilation were to stop and employees do not have sufficient time to exit the space. If there are any changes in the use or configuration of a non-permit confined space that may increase the hazards to entrants, the space shall be re-evaluated and reclassified as a permit required space if necessary. 5.6 Reclassification If a permit space contains no actual or potential atmospheric hazards and if all hazards inside the space are eliminated without entry into the space, the space may be classified as a non-permit confined space for as long as the non-atmospheric hazards remain eliminated. Entry to the space shall be made in accordance with the requirements of Section 4.6 if it is necessary to enter the space to eliminate the hazards. If the testing and inspection during that entry demonstrate the

Page #: 10 of 27 Last Reviewed/Update Date: hazards have been eliminated then the space may be reclassified as a non-permit confined space for as long as the hazards remain eliminated. The use of forced ventilation does not constitute elimination of the hazards. MIT will document the basis for determining that all hazards have been eliminated. The person making the determination shall sign a certification containing the location of the space and the date. The certification shall be made available to each employee entering the space. Should hazards arise in a declassified space all entrants shall exit the space, the space shall be reevaluated to determine whether it must be reclassified as a permit space. 5.7 Periodic Review The confined space program shall be reviewed at least annually by the EHS Office or Entry supervisor for adequacy including the following elements. Completed Entry Permit Forms for the prior year for accuracy and completeness Status of recommended action items based on any problems or hazards encountered or noted on the completed permits Assessment of the need to re-survey the campus, update procedures or re-train individuals participating in the confined space program (Appendix B). MIT shall consult with affected employees on the development and implementation of all aspects of the permit space program and shall make all information required to be developed by 29 CFR 1910.146 available to the affected employees. 6. References / Related Safety Guides 6.1 OSHA 29 CFR 1910.146 Permit Required Confined Spaces 6.2 OSHA Manual and guidance documents 6.3 ANSI Standard Z117.1 Safety Requirements for Confined Space 6.4 Other SOPs / SOGs MIT Control of Hazardous Energy Program Contractor EHS Manual Electrical Safety Management for Facility / Operations Work Environments, EHS 0059 Electrical Safety Management for Research Work Environments, EHS 0060 7. Definitions 7.1 Acceptable entry conditions The conditions that must exist in a permit 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. 7.2 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. 7.3 Authorized entrant

Page #: 11 of 27 Last Reviewed/Update Date: An employee who is authorized by the employer to enter a permit space. 7.4 Blanking or blinding the absolute closure of a pipe, line, or duct by the fastening of a solid plate (such as a spectacle blind or a skillet blind) that completely covers the bore and that is capable of withstanding the maximum pressure of the pipe, line, or duct with no leakage beyond the plate. 7.5 Confined space A space that: (1) Is large enough and so configured that an employee can bodily enter and perform assigned work; and (2) Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and (3) Is not designed for continuous employee occupancy. 7.6 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. 7.7 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. 7.8 Engulfment The surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, or crushing. 7.9 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. 7.10 Entry permit (permit) The written or printed document that is provided by the employer (MIT) to allow and control entry into a permit space and that contains the information specified in paragraph (f) of 1910.146. (Appendix A). 7.11 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

Page #: 12 of 27 Last Reviewed/Update Date: of entry supervisor may be passed from one individual to another during the course of an entry operation. 7.12 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 permit space), injury, or acute illness from one or more of the following causes: (1) Flammable gas, vapor, or mist in excess of 10 percent of its lower flammable limit (LFL); (2) 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. (3) Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent; (4) 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 this Part and which could result in employee exposure in excess of its dose or permissible exposure limit; NOTE: An atmospheric concentration of any substance that is not capable of causing death, incapacitation, impairment of ability to self-rescue, injury, or acute illness due to its health effects is not covered by this provision. (5) Any other atmospheric condition that is immediately dangerous to life or health. NOTE: For air contaminants for which OSHA has not determined a dose or permissible exposure limit, other sources of information, such as Material Safety Data Sheets that comply with the Hazard Communication Standard, section 1910.1200 of this Part, published information, and internal documents can provide guidance in establishing acceptable atmospheric conditions. 7.13 Hot work permit The employer's written authorization to perform operations (for example, riveting, welding, cutting, burning, and heating) capable of providing a source of ignition. Please Contact the MIT EHS office to obtain a hot work permit 7.14 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 space. NOTE: Some materials -- hydrogen fluoride gas and cadmium vapor, for example -- may produce immediate transient effects that, even if severe, may pass without medical attention, but are followed by sudden, possibly fatal collapse 12-72 hours after exposure. The victim "feels normal" from recovery from transient effects until collapse. Such materials in hazardous quantities are considered to be "immediately" dangerous to life or health.

Page #: 13 of 27 Last Reviewed/Update Date: 7.15 Inerting The displacement of the atmosphere in a permit space by a noncombustible gas (such as nitrogen) to such an extent that the resulting atmosphere is noncombustible. NOTE: This procedure produces an IDLH oxygen-deficient atmosphere. 7.16 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. 7.17 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. 7.18 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. 7.19 Oxygen deficient atmosphere An atmosphere containing less than 19.5 percent oxygen by volume. 7.20 Oxygen enriched atmosphere An atmosphere containing more than 23.5 percent oxygen by volume. 7.21 Permit-required confined space (permit space) A confined space that has one or more of the following characteristics: (1) Contains or has a potential to contain a hazardous atmosphere; (2) Contains a material that has the potential for engulfing an entrant; (3) 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 (4) Contains any other recognized serious safety or health hazard. 7.22 Permit-required 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. 7.23 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. 7.24 Prohibited condition

Page #: 14 of 27 Last Reviewed/Update Date: Any condition in a permit space that is not allowed by the permit during the period when entry is authorized. 7.25 Rescue service The personnel designated to rescue employees from permit spaces. At MIT for entry into a PRCS, the Cambridge Fire Department is the designated rescue service. 7.26 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. 7.27 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.

Appendix A: Confined Space Entry Permit Form The MIT DOF Confined Space Entry Permit shall be used in accordance with training and required procedures to evaluate the hazards of each entry, set requirements for entry, and verify that these requirements are present. The permit includes various options and fields needed for completion including the above evaluation as well as signatures and general conditions for use and entry procedures. All areas of the permit form must be completed prior to and during permit-required entries.

MIT CONFINED SPACE ENTRY PERMIT Location Description of Space and, Building Number Permit Number Purpose of Entry: Notify Operations Center 617-253-1500 YES NO Date: Time In: Time Out Expected Expiration Date and Duration: Name of Entrant(s) (Print - use Supplemental Log if necessary) Name of Attendant(s) (Print - use Supplemental Log if necessary) SPECIAL REQUIREMENTS SECTION NOTE: ATTENDANT IS REQUIRED FOR ALL PERMIT-REQUIRED CONFINED SPACE ENTRY! (Check Box) NA YES NO (Check Box) NA YES NO Lockout/Tagout Fall Protection/Life Lines Required Hot Work Permit Hearing Protection Required Lines Disconnected/Blanking Protective Clothing Required Floor & Wall Openings Guarded Retrieval Equip./Tripod/Harness Required Safe Access/Egress Provided Area Secure - Others in Area Alerted Lighting(Explosion-proof/Low Voltage) Communications Established and Checked Backup/Emergency Lighting (Note Method): Overhead Protection Other (list) Additional Ventilation Required? NO YES IF YES: Directed ventilation to point/localized sources using Fans/Blowers/Air Horns Horns Forced ventilation to entire space using: Process Fan(s) Other Fans/Blowers/Air AIR TESTING SECTION (Use Supplemental Log if necessary) Acceptabl e Levels Oxygen-O2 19.5-23.5% Combustibles Carbon Monoxide-CO Hydrogen Sulfide-H2S Air Temperature (if applicable) (Other) (Other) < 10 % LEL < 35 PPM < 10 PPM < 130 F Pre-Entry Results Name of Person Conducting Pre-Entry Air Testing (Print) Periodic Results Initials Time Respiratory Protection: NA ½ Face Full Face Model Periodic Results (Date/Time) Initials Time Air Testing Equipment: Model # Serial # Contractor Air Testing Coordinated? NA YES NO Primary Calibration Information Date Date/Time of Cal/Bump Test Initial s Emergency Rescue Section Contact Operations & Operation Center YES NO Team Name: Cambridge Fire Dept. Contractor Rescue Contact Method: Test Coordinated? Communication NA YES NO Radio: Facilities Channel # 1 Phone #: 617-253-1500 Entry Supervisor Authorization - All PRCS permit conditions have been satisfied and acceptable entry conditions exist. If new hazards arise, the space must be immediately evacuated until the hazard(s) has been eliminated and the space re-evaluated. (Print Name) (Signature) (Date/Time) Entry Supervisor Entry Termination or Cancellation (Print Name) (Signature) (Date/Time) CONTRACTOR DEBRIEFING? NA YES NO Name of Contractor Company(s): Additional hazards encountered during PRCS entry? NO YES (Describe hazards-attach additional information as necessary) Entry Supervisor Verification (Print Name) (Signature) (Date/Time)

PRCS ENTRY AND AIR TESTING SUPPLEMENTARY LOG Acceptable Parameter Periodic Periodic Periodic Periodic Periodic Periodic Periodic Date Time 19.5-23.5% Oxygen% <10% LEL Combustibles% Carbon < 35 PPM Monoxide PPM <10 PPM Hydrogen Sulfide PPM < 130 F Air Temperature (Other) (Other) Tester (Initials) Attendants (List Names Below) Date Time On Date Time Off Entrants (List Names Below) Date Time In Date Time Out Evaluate the space and planned entry work to determine if permit is required** If a permit is required: 1. Look for recognized or known hazards; describe on permit, including all associated data, employees involved in the entry, and respective signatures. Specify all requirements for permitted entry, relative to identified hazards Read and complete all permit areas. See EHS SOP for Working in Confined Spaces 2. If the only recognized or known hazard is atmospheric, alternate entry procedures may be followed. Consult supervisor or EHS. 3. Notify DOF Operations center of intended entry. 4. Verify that all selected permit requirements are present at the time of initial entry. All asterisk items require description or specification in space provided 5 Conduct any specified air monitoring and record as indicated in permit 6. Continue entry activities including communications 7. At end of entry, supervisor must cancel permit and file? ** Generally, spaces that act as a container around the work activity, with restricted means of exit, and not meant to be occupied are basic confined spaces. A Permit-Required confined space (PRCS) is a confined space with known or recognized hazards including: atmospheric, physical/mechanical/stored energy, engulfment, or other serious hazard that could cause illness or injury. PRCSs require specific evaluation of the hazards in and around the space and the work to be done within, and specification of the means to control or eliminate those hazards. For any work that involves significant or complex hazards, this evaluation should be done in advance of the desired entry itself.

Appendix B: Confined Space Annual Program Review Form CONFINED SPACE ENTRY ---- PROGRAM REVIEW Dept/Lab/Center: Rev. Date: Reviewers: #Permits Available: 1. Are all individuals (Entrants, Attendants, and Supervisors) certified and current as to training requirements? 2. Were permits completed accurately? 3. Were any problems noted on permits? If so were the problems resolved? 4. From a sampling of entrants and attendants, do they understand the hazards? Do they personally review the precautions taken? 5. Do contractors bring their own equipment and follow proper procedures? 6. Has Cambridge Fire Department practiced equivalent emergency retrievals in the past 12 months? 7. Is the confined space entry equipment inspected routinely? 8. Is the list of confined spaces complete and up to date? 9. Comments / Suggestions:

Appendix C: List of MIT Campus Confined Spaces A. Boilers with Confined Spaces: Building Room # PM# Building Room # PM# NW10 711341 W8 703983 NW12 703986 W11 NW14 703987 W59 708164 NW14 703988 N42 713078 NW16 704764 N52 703990 NW17 708868 N52 703991 NW21 704722 N52 703992 NW21 704723 E32 703983 NW22 713077 E34 703985 NW30 704724 E51 707115 NW61 700869 E51 707116 W8 703982 B. Electric Manholes: Manhole Number Location/Description 1 Transformer yard West of Power Plant Transformer yard West of Power Plant 1A 3 North side of Vassar St., South of Bldg. 41 4 North Side of Vassar St., South of Xfmr yard at CUP 5 North side of Vassar St., South-West of Bldg. 43 6 Vassar St., South-East of Bldg. 34 7 Vassar St., South-West corner of Bldg. 44 8 Vassar St., across from Bldg. 36 9 Vassar St., across from Bldg. 36 10 Vassar St., across from Bldg. 20E 11 Vassar St., South of Bldg. 48 12 North-West corner of Bldg. 35; Intersection of Mass Ave. and Vassar St. 13 North-West corner of Bldg. 37, Vassar St. 15 North-West corner of Bldg. 39

16 North of Bldg. 38 19 Between S-W corner of Bldg. 39 & N-E corner of Bldg. 31 20 South-East corner of Bldg. 31 21 South of Bldg. 31 22 South-West corner of Bldg. 31, in driveway 24 Mass Ave., North-East corner of Bldg. 37 25 North of Bldg. 13 26 North-West corner of Bldg. 13 27 North-East corner of Bldg. 37 28 North-West of Bldg. 26 29 North-East corner of Bldg. 12 30 Between Bldgs. 12 & 13 31 South of Bldg. 17 32 East of Bldg. 12 33 South-East corner of Bldg. 12 34 Between Bldgs. 12 & 4 35 North of Bldg. 8 36 North-East of Bldg. 8, South of Bldg. 16 37 East of Bldg. 8 38 West of Bldg. 18 41 North-East of Bldg. 56 42 North of Bldg. 56 43 North of Bldg. 56 44 South of Bldg. 56 45 North-West of Bldg. 54 46 North of Bldg. 62 46A South of Bldg. 66 47 North of Bldg. 64 48 East of Bldg. 6 49 East of Bldg. 64 50 North-West of Bldg. 14 51 North of Bldg. 14 52 North-East corner of Bldg. 14 53 North-West corner of Bldg. 50

54 South-West corner of Bldg. 62 55 North-East of Ames St. Tennis Courts 56 North of Bldg. 8 59 Between Bldgs. 24 & 26 E1 In Ames St. sidewalk outside of E19 Xfmr Vault E2 North-West corner of Bldg. E15 E3 In Ames St. sidewalk West of Bldg. E10 E4 Basement of Bldg. E10 E5 North of Bldg. E2 E6 North-East of Bldg. E2 E7 On Amherst St., at Carlton St. E8 On Amherst St. at Hayward St. E9 Bldg. E53 Grounds near Wadsworth St. E11 North-East corner of Bldg. E53 E12 North-East corner of Bldg. E12 E13 North-East corner of Bldg. E35 E14 South of Bldg. 100 Memorial Drive E15 South of National Res. Bldg., Memorial Drive E16 South-West of Bldg. E52 E20 Carlton St. East of Bldg. E32 E21 Carlton St. North-East corner of Bldg. E25 W1 In sidewalk South-East corner of Bldg. W20 W2 West of Bldg. W13(Bexley Hall) W3 Amherst St., North-West of Graduate House W4(West) North of Bldg. W4 in Amherst St.(part of enlarged manhole) W4(East) North of Bldg. W4 in Amherst St.(part of enlarged manhole) W5 West side of Danforth St., corner of Amherst St. W6 South of Auditorium(Transformer Vault) W7 Briggs Field North of Auditorium W8 Between W20 and Briggs Field House W9 South-West of Dupont Athletic Center W10 Vassar St., North of Bldg. 31 W11 Vassar St., North-East corner of Bldg. 33 W12 Vassar St., North of Bldg. 34

W13 Vassar St., between Bldgs. W45 & W41 W15 North of W7(Baker House) in Amherst Alley W16 Amherst St. at Endicott St. W17 Memorial Drive at Bldg. W8(Boat House) W19 North-East of Bldg. W51 W20 Fowler St. W21 North-East of Bldg. W21 W22 North-East corner of Bldg. W70 W23 North of Bldg. W70 W25 Vassar St., North-West corner of Bldg. W34 W26 Briggs Field W27 Vassar St., Briggs Field, across from Bldg. W59 W28 Vassar St., Briggs Field W29 Vassar St., Briggs Field W30 Briggs Field W32 North-West of Bldg. W31 W33 North-East corner of W84(Westgate 2) W34 South-West corner of Bldg. W85 W35 In Amherst St., between Bldgs. W1 and W11 W36 Audrey St., North-West of Bldg. W84 W37 Audrey St., East of Bldg. W91 N1 South of Garage 4, outside of Xfmr vault N2 North-West corner of Bldg. 44 N4 Conrail R. O. W. South of Bldg. N 16 N5 Conrail R. O. W. South of Bldg. N 9 N9 South of Albany St., East of Mass Ave. C. Steam Manholes: Manhole Number Location/Description

E5A E7 E8 E9 E10 E10A E11 E12 E12A E12B E12C E12D E13 E13A Pill Box, between Bldgs. E56 & E60 Memorial Dr. in sidewalk S-E corner of Bldg. E56 Memorial Dr. in sidewalk S-W corner of Bldg. E56 Memorial Dr. in sidewalk S-E corner of Bldg. E51 Amherst St. in sidewalk N-E corner of Bldg. E51 Amherst St. in sidewalk North of Bldg. E51 Amherst St. in sidewalk on South side; at intersection with Hayward St. Amherst St. in sidewalk on South Side; at intersection with Carlton St. Amherst St. in sidewalk on South Side; at N-E corner of Bldg. E2 Amherst St. in grass on North Side; South of Bldg. E23 Carlton St.; East of Bldg. E33 Carlton St. and Deacon St.; at S-W corner of Amherst St. & Ames St. intersection Amherst St. in sidewalk on South Side; North of Bldg. E2 E13B Amherst St. in street on South Side; North of Bldg. E2, just north of manhole E13A E14 E15 Ames St.; between N-W corner of Bldg. E15 and N-E corner of Bldg. 64 In parking lot South of Bldg. E55 H1 Hayward St.; N-W corner of Bldg. E40 100 In sidewalk at N-E corner of Bldg. 6

101 In grass East of manhole 100 102 In grass West of Bldg. 18 103 Under pavers East of Bldg. 18 104 In sidewalk East of Bldg. 6 105 In sidewalk at N-W corner of Bldg. 14 200 In grass East of Bldg. 2 and West of Bldg. 14 202 Under mulch West of Bldg. 14 203 Ames St.; in sidewalk at N-E corner of tennis courts 204 In wall at S-E corner of Bldg E2 ( Hole in the Wall ) 205 Ames St.; in sidewalk South of Bldg. 50 delivery ramp 206 Ames St.; in sidewalk S-E corner of Bldg. 64 207 Ames St.; in sidewalk East of Bldg. 64 301 In street at S-E corner of Bldg. 31 302 In street at S-W corner of Bldg. 24 996 North side of Vassar St. at S-W corner of Bldg. 42 996A North side of Vassar St. at S-W corner of Bldg. 42 998 South side of Vassar St.; North side of Bldg. 35 999 South side of Vassar St.; N-W corner of Bldg. 35 1000 S-E corner of Mass Ave. and Vassar St. intersection 1000A S-E corner of Mass Ave. and Vassar St. intersection 1001 S-W corner of Mass Ave. and Vassar St. intersection 1001A S-W corner of Mass Ave. and Vassar St. intersection 1002 South side of Vassar St.; North side of Bldg. W31