Safety Policy and Procedure Policy Number: 019 Authorized By: The Cianbro Companies Alan Burton Title: Confined Space Entry Effective Date: 02/27/75 Page 1 of 8 1 Status 1.1 Update of existing policy, effective 09/02/11. 2 Purpose 2.1 To provide safe working conditions and environments so no one is exposed to injury or illness from confined or enclosed spaces. 3 Applicability 3.1 This policy applies to all subsidiary companies and departments of The Cianbro Companies. 3.2 All organizations are required to comply with the provisions of this policy and procedure. Any deviation, unless spelled out specifically in the policy, requires the permission of the Corporate Safety Officer or designee. 4 Definitions 4.1 Authorized Entrant: A person approved or assigned by Cianbro to perform a specific type of duty or duties in the confined space. 4.2 Competent Person: One who is capable of identifying existing and predictable hazards in the surroundings or working conditions at the confined space which are unsanitary, hazardous, or dangerous to team members, and who has authorization to take prompt corrective action to eliminate them. 4.3 Confined Space: A space that is large enough and so configured that a person can bodily enter and perform assigned work; and: Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and Is not designed for continuous human occupancy. 4.4 Enclosed Space: Any space, other than a confined space, which is closed in on the sides and overhead. 4.5 Entry Supervisor: A person approved or assigned by Cianbro to assume all supervisory duties at the confined space. 4.6 Hole Watch Attendant: A person approved or assigned by Cianbro to monitor activities and personnel in and around the space. This person is also responsible to take emergency action should something go wrong in or around the space including ordering the entrants out of the space or to notify emergency response personnel if needed. 4.7 Non-permit Required: Non-permit spaces are confined spaces which do not contain nor have the potential to contain, any hazards capable of causing death or serious physical harm, with respect to atmospheric or other hazards. Examples of non-permit spaces would be new construction (excavations, new vessels/pipes, coffer cells) and existing industry spaces where the potential hazards have been eliminated as determined by Cianbro and the host. Policy: 019 Confined Space Entry Rev. 09/02/11 Page 1
4.8 Permit Required: A confined space that has the potential for one or more of the following characteristics: Contains or has a potential to contain a hazardous atmosphere; contains a material that has the potential for engulfing an entrant; has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or contains any other recognized potentially serious safety or health hazard. A qualified Cianbro team member must be responsible for the activity and ALL Ten Basic Rules (section 7.4 of this Safety Policy and Procedure) apply and must be included in the written activity plans. In the case of an existing industry space, a qualified host representative must also be responsible for the activity and ALL Ten Basic Rules must apply at a minimum. 5 Policy 5.1 Team members, subcontractors or others in our control, will follow all requirements of this policy and procedure before, during and after entry into a confined or enclosed space per this policy and the requirements of OSHA standards. 6 Responsibilities 6.1 The top Cianbro manager of the job site is responsible for the implementation of this policy on the project. 6.2 Corporate Safety is responsible for maintaining this document and reviewing recommended changes at least annually. 6.3 Project teams are responsible to report any confined space issues that could warrant a change in our policy to the Corporate Safety Department immediately. Corporate Safety will make the determination as to whether the change is needed and the appropriate timeframe to make the change. Policy: 019 Confined Space Entry Rev. 09/02/11 Page 2
7 Confined Space Entry Index 7.1 Identify All Confined Spaces In The Work Area.... 3 7.2 Confined Space Entry Considerations:... 3 7.3 Hazard Identification And Assessment:... 3 7.4 Ten Basic Rules Applying To Confined Space Entry Work:... 4 7.5 Hole-Watch Attendant Duties:... 6 7.6 Duties Of Authorized Entrants... 7 9 Related Documents... 8 7.1 Identify all confined spaces in the work area. 7.1.1 If applicable, coordinate confined space entry with the host employer to ensure appropriate safety measures are taken in compliance with owner s procedures. OSHA Standards for general industry are more comprehensive and require us to follow more specific guidelines for Permit-Required Confined Spaces. Review prior history of confined space entries and establish encountered problems. 7.2 Confined Space Entry Considerations: Once the work location is identified as a confined space, then distinction must be made whether it is a permit-required or non-permit required space. 7.2.1 Non-Permit Required Non-permit spaces are confined spaces which do not contain nor have the potential to contain, any hazards capable of causing death or serious physical harm, with respect to atmospheric or other hazards. Examples of non-permit spaces would be new construction (excavations, new vessels/pipes, coffer cells) and existing industry spaces where the potential hazards have been eliminated as determined by Cianbro and the host. A qualified Cianbro team member responsible for the activity must determine which of the ten basic rules (section 7.4 of this Safety Policy and Procedure) apply and need to be specifically included in written activity plans. A qualified host representative must concur with the non-permit space determination, if an existing industry space. 7.2.2 Permit Required A permit required confined space has potential for one or more of the following characteristics: Contains or has a potential to contain a hazardous atmosphere; Contains a material that has the potential for engulfing an entrant; Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or Contains any other recognized potentially serious safety or health hazard. A qualified Cianbro team member must be responsible for the activity and ALL Ten Basic Rules (section 7.4 of this Safety Policy and Procedure) apply and must be included in the written activity plans. In the case of an existing industry space, a qualified host representative must also be responsible for the activity and ALL Ten Basic Rules must apply at a minimum. 7.3 Hazard Identification and Assessment: 7.3.1 Determine if work can be done from outside the confined space. Do not enter unless absolutely necessary. 7.3.2 A detailed written activity plan must be generated for all confined space activities. Policy: 019 Confined Space Entry Rev. 09/02/11 Page 3
7.3.3 Activity plans must be developed based on the applicable minimum requirements listed in Section 7.4 of this Safety Policy and Procedure. Additionally, if the work falls under the marine standards, then the requirements of Subpart B of 29 CFR 1915 must be met. 7.3.4 Each item listed in Section 7.4 of this Safety Policy and Procedure must also be evaluated and considered in activity plans if applicable to the type of confined space activity. 7.3.5 Hazard solutions must be clearly stated in the activity plan and reviewed with each team member in the work party before starting work. 7.3.6 Additional planning and coordination must be done in cases where we are required to work with other contractors or client personnel inside the same confined space. We need to ensure that their activities do not have the potential to endanger our team members. 7.3.7 Entry permits must be voided once entry operations are completed or when a review of the permit is required due to the detection of a hazard not covered by the permit, the detection of a condition prohibited by the permit, the occurrence of an injury or nearmiss during entry, a change in the use or configuration of a permit space, or a team member complaint about the effectiveness of the program. A new entry permit will need to be initiated that takes into consideration all new information prior to subsequent entries. 7.4 Ten Basic Rules Applying to Confined Space Entry Work: 7.4.1 Competent Person - A competent person shall be assigned to each confined space activity who is capable of anticipating, recognizing and evaluating team member exposure to hazardous substances or conditions and understands the appropriate emergency procedures. A competent person also has authority to cease operations that pose a threat to workers. In most cases, the entry Supervisor will also be considered the competent person for that activity. 7.4.2 Emergency Planning Prior to entry, plans must be established which provide for entrant rescue/retrieval from a confined space and the quickest possible medical treatment. Whenever possible, non-entry retrieval equipment should be used for rescue to eliminate the need to enter the space during rescue. Rescue by entry is the last resort and requires the following: A minimum of two members of an approved rescue team available to respond in an emergency within 4 minutes. See Confined Space Rescue Safety Policy and Procedure. 7.4.3 Testing of Atmosphere All testing meters/equipment must be calibrated and checked per the manufacturer s recommendations prior to use. Testing must be accomplished for existing or potential atmospheric hazards. OSHA permissible exposure levels (PEL) shall be followed (see limits listed on permits in SD810 and SD811). Continuous or frequent monitoring shall be conducted and results documented. Monitoring shall continue at planned frequency and may be stopped only if the competent person in charge determines it safe to stop. Permits must identify frequency of testing. As a minimum no less than one (1) air test shall be conducted each shift during which any Cianbro team member is working in the confined space. Oxygen must always be checked first because low oxygen levels affect the combustible gas indicator (LEL meter). Oxygen deficient or enriched atmosphere (Must be between 19.5 and 23.0%, (19.5 and 22.0% for marine work)) Flammable or explosive atmosphere (LEL) Toxic atmosphere (H2S, SO 2, CLO, CO, etc.) Other special conditions Policy: 019 Confined Space Entry Rev. 09/02/11 Page 4
Note: For every 0.1% that the oxygen reading is below the normal reading of 20.9%, something has replaced 1000 PPM of the oxygen. For oxygen readings of 20.5 or below you should investigate what is replacing the oxygen. 7.4.4 Lock Out/Tag Out - All electrical and/or mechanical components associated with the confined space must be positively secured. (Pipes blind flanged, breakers padlocked, valves chain locked, etc.) Note: Since OSHA allows the use of a Tag Out system for general industry, some companies, especially electrical generating facilities, have selected the Tag Out for their program. So long as we are assured positive controls are in place, and a coordinated program with the host is established, Tag Out method can be used. 7.4.5 Confined Area Entry Permit - Cianbro s Confined Area Entry Permit must be completed and posted at the access entry of the confined space. The permit must identify the time duration it is good for. In most cases, the permit will only be good for one shift. It may also be necessary to coordinate permitting with the host (owner). The host s permit may be used in place of Cianbro s provided all issues and checks required by Cianbro s program are satisfied. At a minimum Cianbro s Confined Space permit will be used for all confined space work, permit or non-permit. Some Non-Permit spaces may only require an initial (one time) permit that is checked off, good for the duration of work. For permit required confined spaces in general industry, OSHA 1910 Standards must be followed and a sign reading Danger, Permit Required Confined Space - Do Not Enter needs to be posted at each access point. Unless the host has additional requirements, inclusion of all Ten Basic Rules listed in this section will adequately satisfy OSHA S Requirement for Confined Space Work in General Industry. Most host employers in general industry have identified their confined spaces as either Permit required or Non-Permit required confined spaces. Permit required confined spaces includes the need to log workers in and out of a confined space. Use the log provided on the back of the permit form. Log is optional for non-permit spaces unless need is determined by client or competent person. 7.4.6 Hole/Stand-by Watch - A minimum of one person will be assigned sole responsibility for monitoring team members in a permit required confined space to support activities and initiate any emergency actions necessary. New construction like excavations may not require hole/stand-by watch. 7.4.7 Ventilation - Continuous air ventilation/flow must be adequate. Mechanical ventilation must be used any time welding, burning or cutting operations are being performed in a confined space. Minimize bends, kinks or turns in hoses as this greatly reduces airflow. 7.4.8 Tools/Equipment/PPE - Provide for appropriate Personal Protection Equipment for the activity. Explosion proof equipment may be required (GFCI, 12 Volt lights, etc.). 7.4.9 Training Confined Space Training TMs engaged in confined space work as an entry Supervisor, authorized entrant, or authorized attendant (hole watch) must have documented training prior to their first assignment and it is recommended that they have refresher training annually. The training materials can be found on Cianbro.net. Confined Space Rescue Team Training Complete 24hr. Confined Space Rescue Training. -One time training Complete 8 hr. refresher competency rescue training including a mock rescue. Annually Complete an onsite mock rescue Complete medical questionnaire for specific SCBA/SAR approval from our medical director. -Annually Current Pulmonary Function Test (PFT). Every three years Current FIT test specific for SCBA and SAR Annually Current certification in First Aid and CPR Policy: 019 Confined Space Entry Rev. 09/02/11 Page 5
Conduct training with all persons involved in the confined space work activity prior to starting work and as conditions change. The written activity plan must be developed and reviewed with team members and all aspects/hazards discussed. Team members must sign off on the activity plan to document training was conducted. Team members must be proficient in duties expected of them including how to do non-entry rescue if required. Any changes in the original confined space activity plan must be reviewed with team members. 7.4.10 Recordkeeping - Records must be maintained during the activity and filed following the work at the job site. Records should include at minimum: Activity plan Permits (minimum of 1 year) Training conducted Air testing results Emergency Action Plan Special tests conducted Team member signatures of training received Log of team members into and out of confined space for Permit Required spaces Confined space work activities can be extremely dangerous and warrant special emphasis on planning. Should there be unusual circumstances or hazards which require special considerations please contact the Safety Department. 7.5 Hole-watch Attendant Duties: 7.5.1 A hole-watch attendant(s) must stay on duty outside a confined space for the duration of the entry. If they have to leave their post, they must contact their foreman so that he/she can replace them with another qualified hole-watch attendant. NEVER LEAVE A CONFINED SPACE UNATTENDED! Duties include: Keep a count at all times of the number of workers in the space. (Some situations may require the use of a written log to control access in and out of a confined space.) Monitor activities both inside and outside the space. Recognize conditions that could turn into a potential hazard for those in the space. Conduct or assist in air quality monitoring functions. Keep continuous contact with those in the space (visual and/or verbal). 7.5.2 Know how to properly use the emergency equipment and practices WITHOUT entering the space. DO NOT ATTEMPT TO GO INSIDE A SPACE TO PERFORM A RESCUE. 7.5.3 If an emergency arises get help by: Sounding the air horn alarm (2 short blasts) or Using a 2-way radio or Using a cellular phone or Having someone go to a nearby phone to contact appropriate emergency response personnel Have the emergency equipment ready to use. Follow your emergency plan. 7.5.4 Note: In the unlikely event that there is no one else immediately available to contact emergency response personnel, then the hole-watch attendant may leave his/her watch long enough to ensure response personnel are contacted. This assumes that the planned emergency response actions planned for the activity failed, and leaving the hole watch post is a last resort. You should be able to avoid this by providing a radio or cellular phone if an air horn will not work. 7.5.5 The hole-watch attendant has the authority to both fend-off unauthorized intruders and to order entrants out of the space whenever it is necessary. Policy: 019 Confined Space Entry Rev. 09/02/11 Page 6
7.5.6 The hole-watch attendant is to order an evacuation of the space in any of the following five situations: If they see any condition not allowed by the work permit (i.e., hot work, unauthorized work practices, etc.). If they observe changes in personal behavior that could be the result of oxygen deficiency or over exposure to gases/vapors. If they detect a situation(s) outside the space that might endanger those inside (i.e., a chemical spill, or vehicle idling near the ventilation intake, etc.). If they detect an uncontrolled hazard in the space (i.e., exposed and energized circuit, leaking fluid line, etc.). If they have to leave their post for any reason. 7.5.7 A single hole-watch attendant may monitor multiple spaces provided the attendant can keep in continuous contact with those in the spaces (visual or verbal) and plans have been included in the activity plan to ensure emergency response without distractions from the attendant s responsibilities. 7.5.8 Confined space emergency rescue equipment: Some combination of the following equipment will be required for the confined space situation: Air Horn Vertical Lifeline Body Harness Tripod Retrieval System 2-way Radio SCBA Units Stokes Basket w/rigging First Aid Kit Supplied Air with regulator, air lines and respirator Other items as necessary 7.6 Duties of Authorized Entrants 7.6.1 Know the hazards that may be faced during entry, including information on the mode, signs or symptoms and consequences of the exposure. 7.6.2 Proper use of equipment and tools. 7.6.3 7.6.4 7.6.5 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 as necessary in an emergency. Alert the attendant whenever: The entrant recognizes any warning sign or symptom of exposure to a dangerous situation. The entrant detects a prohibited condition. Exit from the permit space as quickly as possible whenever: An order to evacuate is given by the attendant or the entry supervisor. The entrant recognizes any warning sign or symptom of exposure to a dangerous situation. The entrant detects a prohibited condition. An evacuation alarm is activated. Policy: 019 Confined Space Entry Rev. 09/02/11 Page 7
7.6.6 Wear the appropriate PPE for rescue removal if necessary. This may include all, or a combination of the following: Full body harness Retrieval rope Wristlets Flashlight Air monitor Other 8 Budget / Approval Process 8.1 It is the responsibility of each jobsite to procure and provide all materials and PPE required and provide necessary training. 9 Related Documents 9.1 Documents available on Cianbro.net/Resources/Forms Confined Space Entry Hazards and Planning Checklist Permit Required Space Worksheet Non-Permit Required Space Work SD1062 SD810 SD811 9.2 Please Note: Training manual and exam for presenter and student is located on Cianbro.net under Resources Manuals Monthly Safety Training Calendar & Material 9.0 September & 9.1 September & 9.2 September. Policy: 019 Confined Space Entry Rev. 09/02/11 Page 8