(Compliance Audit) Section (c) General Requirements 1) Has the employer performed a workplace inspection to determine if there are Yes No NA permit-required confined spaces (PRCS) present? 2) If the workplace has PRCS, has the employer informed affected employees Yes No NA of their location by posting danger signs at each PRCS location? 3) If local employees will not enter PRCS, has the employer taken effective Yes No NA measures to prevent unauthorized entry? 4) If local employees will enter PRCS, has the employer developed and Yes No NA implemented a written PRCS program that complies with the requirements of the standard? NOTE: The employer may use the PRCS "alternate procedures" below provided the employer can demonstrate that the ONLY hazard posed by a permit space is an actual or potential hazardous atmosphere and that forced-air ventilation ALONE is sufficient to maintain the space safe for entry. If qualified to use the alternate procedures, the employer is relieved of complying with paragraphs (d) through (f) and (h) through (k) respectively. 5) Has the employer developed monitoring data that demonstrates that forced-air Yes No NA ventilation ALONE will render a space safe for entry? 6) If initial entry is necessary in order to obtain the monitoring data required by Yes No NA item (5) above, is such entry performed in full compliance with the standard? 7) Is the monitoring data documented and made available to affected employees Yes No NA or to their authorized representatives? Alternate Entry Procedures 8) Is any condition making it unsafe to remove an entrance cover eliminated before Yes No NA the cover is removed? 9) When an entrance cover is removed, is the opening guarded by a temporary Yes No NA barrier to prevent an accidental fall through the opening and to prevent foreign objects from entering the space? 10) Before entry, is the atmosphere in PRECIS tested with a direct-reading, Yes No NA calibrated instrument in the following order? (a) Oxygen (b) Flammable gases and vapors (c) Toxic air contaminants 11) Are entrants who enter the space, or their authorized representatives, Yes No NA provided with an opportunity to observe the pre-entry testing? 12) There may be no hazardous atmosphere within the space whenever an Yes No NA entrant is in the space? 13) Entrants may not enter the space until forced-air ventilation has eliminated Yes No NA any hazardous atmosphere? 14) Forced-air ventilation is directed to the immediate area where an entrant is or Yes No NA will be? 15) The air supply for forced-air ventilation is from a clean source? Yes No NA 16) The space atmosphere is periodically tested to ensure a safe environment and Yes No NA entrants or their authorized representatives are provided with an opportunity to observe the testing?
17) If a hazardous atmosphere develops during entry: a) Does each entrant leave the space immediately? Yes No NA b) Is the space evaluated to determine how the hazardous atmosphere developed? Yes No NA c) Are measures implemented to protect entrants before any subsequent entry Yes No NA takes place? d) Does the employer verify in writing that the space is safe for reentry? Yes No NA e) Does the written certification contain the date of certification, the space Yes No NA location, and the signature of the person providing the certification? f) Is the written certification made available to entrants or to their authorized Yes No NA representatives? Permit Space Reevaluation 18) When there are significant changes in the use or configuration of a non-permit Yes No NA space, is that space reevaluated and, if necessary, reclassified as a permit space? NOTE: The employer may reclassify a permit space to a non-permit space if the space poses no actual or potential hazardous atmosphere, and if all hazards within the space can be eliminated or controlled without entry. 19) If entry is necessary in order to eliminate hazards, is the entry performed in full Yes No NA compliance with the standard? NOTE: The use of forced-air ventilation to CONTROL the atmosphere does not constitute ELIMINATION of the hazard(s). 20) Does the employer certify in writing the basis for determining that all hazards in Yes No NA the space have been eliminated? 21) Does the written certification contain the date, space location, and name of the Yes No NA person making the determination? 22) Is the written certification made available to entrants or to their authorized Yes No NA representatives? 23) If hazards arise within a space that is classified non-permit, does the employer Yes No NA reevaluate the space to determine if the space should be classified a PRCS? Outside Contractors 24) Does the employer inform contractors of the presence of permit spaces and that Yes No NA entry into such spaces must be performed in compliance with the PRCS standard? 25) Does the employer inform contractors of the elements and identified hazards that Yes No NA make a space PRCS? 26) Does the employer inform contractors of any precautions or procedures taken for Yes No NA the protection of entrants in or near PRCS? 27) Are entry operations coordinated when employees of both the contractor and the Yes No NA employer are working in or near the same PRCS? 28) Does the employer debrief the contractor at the conclusion of entry operations Yes No NA regarding any hazards confronted or created? NOTE: Each contractor is required to accomplish the following: a) Obtain available information from the employer regarding PRCS hazards and local entry operations procedures; b) Coordinate entry operations with the employer when the employees of both parties are working in the same permit space; and c) Inform the employer of any hazards faced or created during entry operations. Section (d) Permit-required Confined Space Program 1) Is the employers' PRCS compliance program in writing? Yes No NA
2) Does the written compliance program document the following information: a) Measures taken to prevent unauthorized entry? Yes No NA b) Action taken to identify and evaluate permit space hazards before entry takes Yes No NA place? c) The procedures and practices necessary for safe permit space entry? Yes No NA d) Acceptable entry conditions? Yes No NA e) A provision that each entrant or his authorized representative is provided with Yes No NA the opportunity to observe any monitoring or testing of permit spaces? f) How permit space hazards will be controlled or eliminated? Yes No NA g) Procedures to provide pedestrian, vehicular, or other necessary safety Yes No NA barriers? h) How conditions in a permit space are verified as acceptable for entry? Yes No NA i) A statement that the following equipment will be provided, and that such equipment will be in good condition and used properly: * Testing equipment; * Ventilating equipment; * Communications equipment; * PPE; * Lighting equipment; * Barriers, shields, etc; * Ladder; and * Necessary emergency rescue equipment; and * Any other equipment identified as necessary for safe entry operations? Yes No NA j) How a permit space will be tested to ensure that acceptable entry conditions Yes No NA are being maintained during entry operations? k) That permit space atmospheric testing will be conducted in the following order: Yes No NA * Oxygen; * Combustible gases and vapors; then * Toxic gases and vapors. l) Procedures to ensure that entrants or their authorized representative are Yes No NA provided with an opportunity to observe pre-entry testing and any subsequent testing or monitoring of permit spaces? m) That at least one attendant will be provided outside permit spaces during entry Yes No NA operations? n) The procedures the space attendant will follow if he is to monitor more than Yes No NA one permit space at a time? o) The names of persons who will perform the roles of space attendant, authorized Yes No NA entrant, entry supervisor, and person(s) who will be responsible for monitoring the space atmosphere? p) Procedures for summoning rescue and emergency services and for preventing Yes No NA unauthorized personnel from attempting an emergency rescue? q) Procedures for developing and implementing a system for the preparation, Yes No NA issuance, use, and cancellation of entry permits? r) Procedures to coordinate entry operations when local employees and contractor Yes No NA employees are working in a permit space at the same time? s) Procedures for closing off permit spaces and canceling the entry permit at the Yes No NA conclusion of entry operations? t) A requirement that the employer will review and revise the written PRCS program Yes No NA if the employer detects any deficiencies in the program? u) A requirement that the employer will conduct a review of the PRCS program at Yes No NA least annually using cancelled permits as the basic review information?
Section (e) Permit System 1) Does the employer prepare and issue a permit for all permit space entry operations? Yes No NA 2) Does the entry supervisor sign the permit to authorize entry? Yes No NA 3) Is the completed permit made available to all authorized entrants or to their Yes No NA authorized representatives? 4) Is the duration of the permit restricted to the amount of time required to perform Yes No NA the entry assignment? 5) Does the entry supervisor cancel the permit under the following conditions: a) When entry operations covered by the permit have been completed? Yes No NA b) If a condition not allowed by the permit arises in or near the permit space? Yes No NA 6) Does the employer retain entry permits for at least one year? Yes No NA 7) Are any problems encountered during entry operations noted on the entry permit? Yes No NA Section (f) Entry Permit 1) Does the entry permit identify at least the following: a) The permit space to be entered; b) The purpose of entry; c) The date and authorized duration of the permit; d) The identity of the authorized entrant(s); e) The identity of the space attendant; f) The identity of the entry supervisor; g) The identified hazards of the space to be entered; h) The measures that will be used to isolate the space and to eliminate or control atmospheric hazards before entry; i) Acceptable entry conditions; j) The results of previous testing including the identity of the person who performed the tests; k) The rescue and emergency services that can be summoned and the means to do so; l) The procedures that will be employed to maintain contact between entrant and entry attendants; m) The equipment identified as necessary for safe entry and egress; and n) Any additional permits (such as for hot work) that have been issued to Yes No NA authorize work in the space? Section (g) Training 1) Is training provided as follows: a) Before employees perform permit space work; b) Before there is a change in assigned duties; c) When there is a change in permit space hazards; and d) Whenever the employer has reason to believe that the requirements of the Yes No NA permit space program are not being followed properly? 2) Does the employer certify in writing that the required training has been followed? Yes No NA 3) Does the written certification contain the name(s) of those employees who have Yes No NA received training; the date the training was provided; and the signature of the trainer? Section (h) Duties of Authorized Entrants 1) Do authorized entrants know the hazards that may be faced during entry, Yes No NA including the mode, signs, or symptoms of exposure? 2) Are entrants required to use the entry equipment properly? Yes No NA 3) Do entrants communicate with the space attendant as necessary to enable the Yes No NA attendant to properly monitor entrant status?
4) Do entrants alert the space attendant whenever: a) Entrants recognize any warning sign or symptom of exposure to a dangerous situation; or b) When entrants detect a prohibited condition? Yes No NA 5) Do entrants exit the space whenever an order is given to evacuate by the Yes No NA attendant or the entry supervisor, or whenever an alarm is sounded? Section (i) Duties of Attendants 1) Do attendants know the hazards that may be faced during entry, including the Yes No NA mode, signs, or symptoms of exposure? 2) Are attendants aware of possible behavorial effects of hazard exposure in Yes No NA entrants? 3) Do attendants maintain continuous contact with authorized entrants? Yes No NA 4) Do attendants remain outside the space until properly relieved by another Yes No NA attendant? 5) Do attendants monitor the activities within the space and order an evacuation under any of the following conditions: a) If the attendant detects a prohibited condition; b) If the attendant detects any effects of hazard exposure in an entrant; c) If the attendant detects a situation outside the space that could endanger an entrant; or d) If the attendant cannot effectively and safely perform the duties of a permit Yes No NA space attendant? 6) Does the attendant summon rescue and emergency services when the attendant Yes No NA determines that an entrant is in need of assistance to escape from a permit space? 7) Does the attendant take the following action when unauthorized persons approach or enter a permit space: a) Warn the unauthorized person to stay away from the space; b) Advise the unauthorized person to exit immediately if he has entered the permit space; and c) Inform authorized entrants and the entry supervisor that an unauthorized person Yes No NA has entered the permit space? 8) Does the attendant perform non-entry rescue as needed? Yes No NA 9) Does the attendant restrict himself to the primary duty of monitoring and protecting Yes No NA entrants? Section (j) Duties of Entry Supervisor 1) Does the entry supervisor know the hazards that may be faced during entry, Yes No NA including the mode, signs, or symptoms of exposure? 2) Does the entry supervisor check the entry permit to ensure the following: a) All of the required tests have been performed; and b) All required procedures and equipment are in place? Yes No NA 3) Does the entry supervisor terminate the entry permit when entry operations have Yes No NA been completed? 4) Does the entry supervisor certify that emergency services are available and that Yes No NA the means to summon them is operable? 5) Does the entry supervisor remove unauthorized persons who enter or attempt to Yes No NA enter a permit space? 6) Does the entry supervisor determine that entry operations remain consistent with Yes No NA the terms of the permit?
Section (k) Rescue and Emergency Services * Outside Service 1) Does the employer evaluate a prospective rescuer's ability to respond to a rescue Yes No NA summons in a timely manner, considering the hazard(s) involved? 2) Does the employer evaluate the prospective rescuer's ability, in terms of Yes No NA proficiency with rescue-related task and equipment, to function appropriately while engaged in rescue operations? 3) Has the employer selected a rescue service from those evaluated that: a) Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified; b) Is equipped for and proficient in performing the needed rescue services? Yes No NA 4) Does the employer inform the outside rescue service of the hazards they may Yes No NA confront during an onsite emergency rescue? 5) Is the outside rescue service selected given access to all permit spaces so that Yes No NA the service can develop appropriate rescue plans and practice rescue operations? Inside Service 6) Are entrants provided with the personal protective equipment needed to conduct Yes No NA permit space rescues safely and trained so that they are proficient in the use of that equipment? 7) Have entrants successfully completed the training required by the PRCS standard? Yes No NA 8) Are entrants trained in basic first-aid and CPR? Yes No NA 9) Does at least one member of the rescue team hold current certification in first aid Yes No NA and CPR? 10) Does the rescue team practice permit space rescues at least annually, in which Yes No NA they remove dummies, manikins, or actual persons from representative permit spaces? 11) Are retrieval systems or methods used whenever an authorized entrant enters a Yes No NA permit space, unless the retrieval system would increase the overall risk of entry to the entrant? 12) Does each entrant use a chest or full body harness, with a retrieval line attached at Yes No NA the center of the entrant's back near shoulder level above the entrant's head, or at another point which presenta a profile small enough for the successful removal of the entrant? 13) Is the other end of the retrieval line attached to a mechanical device or fixed point Yes No NA outside the permit space in such a manner that rescue can begin as soon as the rescuer becomes aware that rescue is necessary? 14) Is a mechanical retrieval device available to retrieve entry personnel from Yes No NA vertical type permit spaces more than 5 feet deep? 15) If an injured entrant is exposed to a substance for which there is an MSDS or other Yes No NA similar information, is that information provided to the treating medical personnel? Section (l) Employee Participation 1) Does the employer consult with affected employees and their authorized Yes No NA representatives on the development and implementation of all aspects of the permit space program required by the standard? 2) Are affected employees and their authorized representatives furnished the Yes No NA necessary information required by the standard? Prepared by Adam Schupp, safety consultant, N. Ft. Myers, FL; 941-731-5947.