Page 1 of 14 Sect: 1.0 Purpose 2.0 Scope The Confined Space Entry Policy and is provided to protect authorized employees that will enter confined spaces and may be exposed to hazardous atmospheres, engulfment in materials, conditions which may trap or asphyxiate due to converging or sloping walls, or contains any other safety or health hazards. All company operations shall use the Confined Space Entry, both in business units and project operations, whenever employees are required to enter confined spaces. 3.0 Regulatory References This Confined Space Entry is intended to satisfy the following regulatory requirements: 29 CFR 1910.146, OSHA-Permit-Required Confined Spaces 4.0 Responsibilities 4.1 Management Ensure proper training for entry personnel Provide proper equipment for entry personnel at no cost to the employees and assure that it is maintained and used properly. Ensure confined space assessments have been conducted Annually review this program and revise as necessary. 4.2 Employees Follow program requirements Report any previously un-identified hazards associated with confined spaces
Page 2 of 14 Sect: 4.3 Entry Supervisor Entry supervisors are responsible for the overall permitted space entry and must coordinate all entry procedures, tests, permits, equipment and other relevant activities. The following entry supervisor duties are required: o Know the hazards that may exist during entry, including information on the mode, signs or symptoms, and consequences of the exposure. o Verify, by checking that the appropriate entries have been made on the permit, all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin. o Terminate the entry and cancel the permit when the entry is complete and/or there is a need for terminating the permit. o Verify that rescue services are available and that the means for summoning them are operable. Prevent unauthorized persons from entering the confined space during entry operations. o Determine whenever responsibility for a permit space entry operation is transferred and at intervals dictated by the hazards. Also, operations performed within the space remain consistent with the permit terms and that acceptable entry conditions are maintained. o Review permit process and institute revisions whenever deficiencies are discovered. o Assure that entrant personnel have had the opportunity to observe all atmosphere testing. o Re-evaluate permit in the event any entrant personnel suspects that conditions have changed. 4.4 Entry Attendants At least one attendant is required outside the permit space into which entry is authorized for the duration of the entry operation. The attendant will be assigned to only one permit space. Responsibilities include: o Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure. o Be aware of possible behavioral effects of hazard exposure on entrants. o Continuously maintain an accurate count of entrants in the permit space and ensure a means to accurately identify authorized entrants.
Page 3 of 14 Sect: 4.5 Entrants o Remain outside the permit space during entry operations until relieved by another attendant (once properly relieved, they may participate in other permit space activities, including rescue if they are properly trained and equipped). o Communicate with entrants as necessary to monitor entrant status and alert entrants of the need to evacuate. o Monitor activities inside and outside the space to determine if it is safe for entrants to remain in the space and order the entrants to immediately evacuate if the attendant detects a prohibited condition, detects entrant behavioral effects of hazard exposure, detects a situation outside the space that could endanger the entrants; or if the attendant cannot effectively and safely perform all the attendant duties. o Summon rescue and other emergency services as soon as the attendant determines the entrants need assistance to escape the permit space hazards. o Perform non-entry rescue as specified by the rescue procedure and entry supervisor o Not perform duties that might interfere with the attendants' primary duty to monitor and protect the entrants. o Take the following action when unauthorized personnel approach or attempt to enter a permit space while entry is under way:.1.1 Warn the unauthorized persons that they must stay away from the permit space,.1.2 Advise unauthorized persons that they must exit immediately if they have entered the space, and.1.3 Inform the authorized entrants and the entry supervisor if unauthorized persons have entered the permit space. The entry supervisor must authorize all entrants to enter permit spaces. All entrants must have received the required training, use the proper equipment, and observe the entry procedures and permit. The following entrant duties are required: o Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure; o Properly use the equipment required for safe entry; o Communicate with the attendant as necessary to enable the attendant to monitor the status of the entrants and to enable the attendant to alert the entrants of the need to evacuate the space if necessary;
Page 4 of 14 Sect: 5.0 Hazards o Alert the attendant whenever the entrant recognizes any warning signs or symptoms of exposure to a dangerous situation, or any prohibited condition is detected; and o Exit the permit space as quickly as possible whenever the attendant or entry supervisor gives an order to evacuate the permit space, the entrant recognizes any warning signs or symptoms of exposure to a dangerous situation, the entrant detects a prohibited condition, or an evacuation alarm activated. Explosive / Flammable Atmospheres Toxic Atmospheres Engulfment Asphyxiation Entrapment Slips & falls Chemical Exposure Electric Shock Thermal / Chemical Burns Noise & Vibration 6.0 Hazard Control 6.1 Engineering Controls Locked entry points Temporary ventilation Temporary Lighting Equipment suitable for hazards (i.e., explosion proof, intrinsically safe) 6.2 Administrative Controls Signs Employee training Entry procedures Atmospheric Monitoring Rescue procedures Use of prescribed PPE
Page 5 of 14 Sect: 7.0 Definitions 7.1 Acceptable Entry Conditions - 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 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. 7.3 Authorized Entrant - an employee who is authorized to enter a confined space. 7.4 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. 7.5 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. 7.6 Entry Permit - a written or printed document authorizing controlled entry into a permit space. Permits shall contain minimum information as specified in section 10.2 of this document. 7.7 Entry Supervisor authorized person responsible for: Determining if acceptable entry conditions are present at a permit space Authorizing entry Overseeing entry operations Terminating entry as required NOTE: An entry supervisor also may serve as an attendant or as an authorized entrant, if that person is trained and equipped as required by this section for each role he or she fills. Also, the duties of entry supervisor may be passed from one individual to another during an entry operation. 7.8 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. A confined space may be deemed as a non-permitted confined space only if the following conditions exist: All physical hazards in the space have been eliminated or isolated through engineering controls Continuous forced air ventilation provides for safe entry
Page 6 of 14 Sect: Continuous monitoring will be in place unless supporting data can demonstrate that continuous monitoring is unnecessary. If changes occur at any time inside of a non-permitted confined space that might increase the hazards to entrants, a competent person must re-evaluate the space and reclassify as a permit-required space if necessary. 7.9 Permitting Authority a qualified/competent person capable of recognizing the hazards associated with the types of confined spaces encountered and the methods/procedures for controlling such hazards. This person shall also be authorized by management to issue confined space entry permits. If more than one entity will be entering a permit-required confined space, coordination between the controlling contractor and the entry employer must occur to avoid activities that could result in hazards within the space. 7.10 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 4) Contains any other recognized serious safety or health hazard. Each Permit-Required Confined Space will be marked "Confined Space - Entry Permit Required". 8.0 Permit Required Confined Space Entry General Rules During all Permit-Required Confined Space Entries, the following Safety Rules must be strictly enforced: 1) A hazard assessment of the permit required confined space must be performed. 2) Only Authorized and Trained Employees may enter a Confined Space or act as Attendants. 3) No Smoking is permitted in a Confined Space or near entrance/exit area. 4) During Confined Space Entries, Attendants must be present at all times. 5) Constant visual or voice communication will be maintained between the Safety Attendants and Employees entering a Confined Space for continuously verifying that conditions in the permit space are acceptable. 6) No bottom or side entry will be made or work conducted below the level of any hanging material or material which could cause engulfment.
Page 7 of 14 Sect: 7) Atmospheric testing is required before entering any Permit-Required Confined Space. Oxygen levels in a Confined Space must be between 19.5 and 23.5 percent. Levels above or below will require the use of an SCBA or other approved air supplied respirator. Additional ventilation and Oxygen Level Monitoring is required when welding is performed. The monitoring will check Oxygen Levels, Explosive Gas Levels, and Carbon Monoxide Levels. Entry will not be permitted if explosive gas is detected above one-half the Lower Explosive Limit (LEL). 8) Attendants shall protect entrants from external hazards such as pedestrians and vehicular traffic by maintaining barriers and warning individuals or vehicles that move toward the immediate space of the entry point. 9) To prevent injuries to others, all openings to Confined Spaces will be protected by a barricade when covers are removed. 9.0 Confined Space Entry Procedures A competent person shall evaluate all potential confined spaces to determine if a Confined Space Entry Permit is required. For those spaces determined to be Permit Required Confined Spaces, a Confined Space Entry Permit shall be required. 9.1 Authorized Participants - Each employee who enters or is involved in the entry shall: 1) Be authorized by the Entry Supervisor 2) Understand the procedures for confined Space Entry 3) Know the Hazards of the specific space 4) Review the specific procedures for each entry 5) Understand how to use entry and rescue equipment 6) Sign the Entry Permit 9.2 Air Quality Tests All entrants shall be provided an opportunity to review air quality monitoring results. Air quality monitoring shall be conducted periodically during the entry operation to ensure air quality remains acceptable. Frequency of testing shall be determined by a competent person based on the hazards encountered. 9.3 Ventilation A means of ventilation shall be provided during the confined space entry operation. 9.4 Communication A means of communication between the entrants and the attendants shall be provided throughout the confined space entry operation. 9.5 Alarm & Summonsing Help A means of alarm and summonsing emergency services shall be provided and available throughout the confined space entry
Page 8 of 14 Sect: operation. The method shall not distract or impact the attendant s ability to fulfill monitoring responsibilities. 9.6 Emergency Services: 1) Must be provided by: The host facility An outside service which is given the opportunity to examine the entry site, practice rescue and decline if necessary Provided by the employer by selecting a rescue team that is equipped and trained to perform the needed rescue services. 2) Must be aware and accept their role as emergency response and rescue for the duration of the entry operation. 3) Must be competent and qualified to perform tasks required. 4) Respond to alarms and rescue summons in a timely manner given the hazards identified within the confined space. 5) Are familiar with or have reviewed the entry procedure and entry site. 6) Be properly equipped and proficient in rescue techniques / requirements given the hazards identified within the confined space. 7) Shall be provided an opportunity to practice rescue services if the emergency response team deem it necessary. At least one standby person must be at the site who is trained and immediately available to perform rescue and emergency services for any permit-required confined space, including those with IDLH atmospheres. 9.7 Non-Entry Rescue For entries where non-entry rescue is part of the emergency response and rescue plan and the retrieval system or method does not increase the overall risk of entry then the retrieval system shall include the following: 1) The non-entry retrieval system shall include a full body harness with retrieval line attached near the entrant s back centered between the shoulders. 2) The retrieval line shall be attached to a mechanical device positioned and fixed outside the permit space. 3) The system shall allow for immediate rescue as soon as the attendant becomes aware of an emergency. Such non-entry retrieval systems shall be required for vertical type permit spaces more than 5 feet deep.
Page 9 of 14 Sect: 9.8 First Aid & First Aid Equipment Personnel capable of providing first aid and CPR shall be available until emergency medical services arrive. This or these individuals need not be directly involved in the confined space entry operation but must be capable of being summonsed without distracting or impacting the attendant s ability to fulfill monitoring responsibilities. First aid equipment shall be readily available. 9.9 Signs & Barricades Requirements for signs and barricades shall be determined prior to start of entry operations. Materials and equipment, for posting hazard notices and erecting controlled access area barricades, shall be provided and installed prior to start of entry operations. 9.10 Re-entry See Review and Re-entry section 10.7 below. 9.11 Un-authorized Entry Entry into confined spaces by un-authorized personnel is prohibited including emergency assistance or rescue attempts. Signs and barricades shall be erected to prevent the accidental entry of un-authorized individuals. Attendants shall also guard against the intrusion of un-authorized individuals into the confined space and warn entrants if such intrusions present a risk that may require the entry be terminated. Ardent employees committing unauthorized entries or intrusions shall be subject to disciplinary action up to and including termination of employment. 9.12 Re-evaluation of Permitted Space If an entrant or entrant s representative believes that the evaluation is not adequate or changes have occurred, they shall have the right to request a re-evaluation. The results of the re-evaluations shall be immediately provided to the requesting party. A permit-required confined space may be re-classified as a non-permit confined space only if all the following criteria have been met: The space poses no actual or potential atmospheric hazards and all hazards have been eliminated or isolated. Testing and inspection demonstrates that all hazards or potential hazards have been eliminated or isolated. Forced air ventilation does not constitute elimination or isolation of the hazards The competent person making the determination certifies the determination in writing with the date, location and time of the reclassification and signs the certification If a hazard arises at any time in a non-permitted confined space, all employees must exit the space immediately and the space must be re-evaluated and reclassified as a permit-required space.
Page 10 of 14 Sect: 10.0 Confined Space Entry Permits 10.1 Permitting Authority A single entity shall be identified as the permitting authority. The Permitting Authority may be the responsible unit operator, area safety representative, senior supervisor, on site manager or facility coordinator. The Permitting Authority shall be a qualified/competent person capable of recognizing the hazards associated with the types of confined spaces encountered and the methods/procedures for controlling such hazards. This person shall also be authorized by management to issue such permits. For confined space entry situations involving multiple companies and/or craft disciplines, a single-entry procedure and Permitting Authority shall be mutually agreed to by all parties. Ardent employees are prohibited from participating in confined space entry operations where multiple procedures are in place. 10.2 Permit Preparation & Issue Permits must be prepared and issued by the Permitting Authority. 10.3 Confined Space Entry Permits - shall be completed before any Employee enters a Permit-Required Confined Space. The Permit must be completed and signed by an Authorized Site Representative before entry. Permits will expire prior to end of shift. Before the completion of the shift or if any pre-entry conditions change Permits will be maintained on file for 12 months. 10.4 Permit Information - Permits shall contain the following minimum information: Identifies the specific space being entered Purpose for the entry Date, duration and expiration of entry and entry permit Names of entrants Names of attendants Name of entry supervisor Name of the Permitting Authority Hazards of the space Hazard control means Acceptable entry conditions Initial atmosphere test results Means of alarm and emergency response
Page 11 of 14 Sect: Means of communication between entrants and attendants PPE required Special requirements (testing, equipment, controls, procedures, etc.) 10.5 Attendants and Multiple Spaces Wherever possible, each confined space entry will have a dedicated attendant. If circumstances should require a single attendant to monitor multiple confined spaces, then the Entry Permit and Emergency Response Plan shall include provisions allowing the attendant to respond to and/or summon help to an emergency in one space without distracting or impacting the attendant from fulfilling responsibilities for other spaces being monitored. 10.6 Canceling Entry Permits In addition to the entry supervisor s authority to terminate entry at any time, the Permitting Authority may cancel a confined space entry permit at anytime. Following are conditions or circumstances which may be considered grounds for canceling the Entry Permit: Conditions outside the confined space have changed, such as weather, air quality, light or other work activities. Conditions inside the confined space have changed, such as air quality conditions, light, communications, etc. General alarm or evacuation of the area. Emergency medical services and rescue are responding to another emergency or otherwise no longer able to respond as planed. An incident, unauthorized entry or near miss occurs during the confined space entry operation, or permit period. Attendant is unable to fulfill duties. New hazards are discovered inside or outside the confined space that were not covered by the existing JSA or Entry Permit. Work is completed with substantial time remaining on the permit. Once a Confined Space Permit is cancelled, the entry shall be sealed (if possible) and the approved procedure for handling permits shall be followed. All cancelled entry permits must be reviewed and retained for at least 1 year. 10.7 Review and Re-entry In the event an entry operation and/or permit is cancelled for any of the reasons listed above, the entry procedure must be reviewed and hazard control methods determined for any new hazards or conditions prior to re-entry or re-issue of the Confined Space Permit.
Page 12 of 14 Sect: 11.0 Subcontractor Entry All work by non-ardent employees that involves the entry into confined spaces will follow the procedures of this program. The information of this program and specific hazards of the confined spaces to be entered will be provided to the Subcontractor Site Supervisor prior to commencing entry or work. The scope of work of each craft will be evaluated and coordinated to prevent endangerment of the others employees. 12.0 Confined Space Hot Work On those occasions that hot work must be conducted in confined spaces, all entries and work shall be conducted in accordance with the Confined Space Entry or the Confined Space Work Permit Procedure mutually agreed to by Ardent and client for use in a client s facility. Please see the latest copy of Ardent s Hot Work Safety and Procedures, HSE Manual Section B.29, document O-SS-SPP-0030. Also, see Ardent s Work Authorization (Permit to Work), HSE Manual Section B.33, document O-SS-SPP-0033. 13.0 Training All Ardent employees shall be trained in Confined Space Hazard Awareness and safety awareness as part of the Short Service Employee. Ardent employees required to participate in Confined Space Entry operations shall be trained in Confined Space Entry. This training shall be a stand alone training module and shall be instructed by a qualified/competent individual capable of recognizing the hazards associated with confined spaces and the methods and procedures used to control these hazards prior to being assigned duties and/or prior to a change in assigned duties. 13.1 Training for Confined Space Entry includes: 1) Duties of Entry Supervisor, Entrant, and Attendants 2) Confined Space Entry permits 3) Hazards of Confined Spaces 4) Use of Air Monitoring Equipment 5) First Aid and CPR Training 6) Emergency Action & Rescue Procedures
Page 13 of 14 Sect: 7) Confined Space Entry & Rescue Equipment 8) Rescue training, including entry and removal from representative spaces 13.2 Training points for Confined Space Hazards Awareness 1) Flammable Atmospheres enriched oxygen, flammable vapors, work byproducts, chemical reaction, combustible dust and residual flammable products. 2) Toxic Atmospheres chemical or organic gases, vapors and fine airborne dust. 3) Corrosive Atmospheres Irritant corrosives include chlorine, hydrochloric acid, hydrofluoric acid, sulfuric acid, nitrogen dioxide, ammonia, etc. 4) Asphyxiation Atmospheres Deficient oxygen through oxygen consumption or displacement, atmospheres of non-toxic inert gases such as nitrogen, helium, carbon dioxide and argon. 5) Mechanical Hazards Moving parts, electrical equipment, static electricity discharge, 6) Thermal Hazards Radiant heat, inadequate heat dissipation, extreme cold, etc. 7) Noise Reverberating noise, difficulty communicating, inability to hear warning signals. 8) Vibration Platform and/or equipment vibration can cause whole body fatigue and numbness, localized body part pain and numbness caused by power tools. 9) Other Hazards Slips, trips, falls, body strains, falling objects, insufficient light or visibility, overexertion, awkward positions and static postures. 13.3 Training Frequency Confined Space Hazard Awareness training shall be included in New Employee Orientation and Ardent s Short Service Employee which will cover Confined Space Hazard Awareness within the first 180 days of employment. Confined Space Hazard Awareness will be refreshed annually as part of the Toolbox Safety Training. Confined Space Entry & Procedures training shall be initiated prior to any employee s initial assignment to a Confined Space Entry operation. Training shall be refreshed or retraining shall be required if: 1) Employee s Confined Space Entry training or refresher training is more than one year old.
Page 14 of 14 Sect: 2) If new hazards have been recognized or created that were not covered by the pervious Confined Space Entry training. 3) If the employee s duties are changed to duties not covered by the pervious Confined Space Entry training. 4) The Confined Space Entry permit or procedure has changed and includes activities or special deviations not covered by the pervious training. 14.0 Reporting & Recordkeeping 14.1 Training - All training completed in this section will be documented and will contain the following information: Employee Name Date of Training Instructors Name and Signature This information will be available to the employee and employee s authorized representative. 14.2 Reports All confined space entry incidents shall be reported. 14.2.1 Incident Report - All confined space entry events resulting in injury, illness, or loss of consciousness of an employee shall be recorded as Incidents on an Ardent Incident/Accident Report. 14.2.2 Near Miss Reports - Failures in control methods not resulting in employee injury or illness shall be recorded as near miss events on an Ardent Near Miss Report. Examples: Employee enters a confined space without confined space entry permit or attendant. Or, attendant leaves confined space entry operation unattended. 15.0 Attachments 15.1 Appendix A, Confined Space Entry Permit, document number O-SS-FRM- 120