IEA, INC. B E M I D J I A R E A S C H O O L S Contact Us: BROOKLYN PARK OFFICE 9201 W. BROADWAY, #600 BROOKLYN PARK, MN 55445 763-315-7900 MANKATO OFFICE 610 N. RIVERFRONT DRIVE MANKATO, MN 56001 507-345-8818 Management Plan for Confined Spaces ROCHESTER OFFICE 210 WOOD LAKE DRIVE SE ROCHESTER, MN 55904 507-281-6664 BRAINERD OFFICE 13432 ELMWOOD DRIVE, STE. #5 BAXTER, MN 56425 218-454-0703 MARSHALL OFFICE 1420 EAST COLLEGE DRIVE MARSHALL, MN 56258 507-476-3599 NOVEMBER 2015 NORTHEAST OFFICE 5525 EMERALD AVENUE MT. IRON, MN 55678 218-410-9521 www.ieasafety.com info@ieasafety.com 800-233 233-9513 IEA Project #201510496
Bemidji Area Schools Management Plan for Confined Spaces Table of Contents Annual Review Form 1.0 Introduction... 1 2.0 Program Responsibilities... 1 2.1 Contact Person... 1 2.2 Confined Space Entry Supervisors... 1 2.3 Confined Space Authorized Entrants... 2 2.4 Confined Space Attendants... 2 3.0 Workplace Confined Space Evaluations and Reclassification... 2 4.0 Identification of Confined Spaces... 3 5.0 Entry Procedures for Permit-Required Confined Spaces... 3 6.0 Contractor Guidelines... 5 7.0 Non-Permit-Required Confined Spaces... 5 8.0 Ventilation of Confined Spaces... 5 9.0 Equipment Used In Confined Spaces... 6 10.0 Emergency Service Confined Space Rescue... 6 11.0 Employee Training... 7 12.0 Recordkeeping... 7 13.0 Annual Review... 8 Appendices: A Confined Space Assessments and Inventory B Confined Space Entry Permit (For Contractors) C Reclassification Records Contact Person: Steve Spindler Phone Number: 218-766-5466 Email Address: sspindler@bemidji@k12.mn.us
*Bemidji Area Schools* Annual Review Form *Management Plan for Confined Spaces* Certification I certify that I have reviewed the information provided and accept this written management plan. With assistance from our EHS consultant, the district will implement the policies and procedures noted within this plan. The written plan is a working document that will be reviewed and revised annually, or as needed. Print Name Signature Date Program reviews and follow-up of program-related issues are documented below. Date Actions/Comments Reviewed by:
Bemidji Area Schools IEA Project #201510496 Management Plan for Confined Spaces November 2015 1.0 Introduction Bemidji Area Schools is committed to providing a safe and healthy workplace for all employees. As part of routine maintenance, our employees and contractors are occasionally required to enter potentially hazardous enclosed spaces. The purpose of this written program is to provide information and guidance for safe entry into confined spaces and to comply with OSHA Standard 29 CFR 1910.146 Permit- Required Confined Spaces. Confined spaces meet all of the following conditions: the space is large enough to bodily enter and perform work, the space has limited means of entry and egress, and the space is not designed for continuous worker occupancy. A confined space may require a permit if the space contains, or has the potential to contain, a hazardous atmosphere; contains a material that has the potential to engulf an entrant; has a hazardous internal configuration; or contains any other recognized serious safety or health hazard. 2.0 Program Responsibilities 2.1 Contact Person Bemidji Area Schools has identified Steve Spindler, the Safety, Warehouse and Purchasing Manager, as the contact person for the confined space program. The responsibilities of the confined space contact person as it pertains to this program, include the following: Conduct/coordinate hazard assessments to determine confined space locations and associated hazards. Determine the space classification (permit-required or non-permit space). Post appropriate danger/caution signs by each confined space. Coordinate and/or conduct supervisory and employee training and maintain records. Enforce employee compliance with the confined space entry program. Provide appropriate PPE and equipment and train staff on its proper use and maintenance. Select qualified individuals as Confined Space Entry Supervisors, entrants, and attendants. Provide confined space entry personnel with a copy of the most current confined space entry program and update staff as necessary. Maintain completed entry permits. 2.2 Confined Space Entry Supervisors Trained Maintenance staff have been designated and trained as Confined Space Entry Supervisors. The responsibilities of these individuals are as follows: Know the hazards and potential hazards that may be encountered during entry and inform entrants about the hazards, including information on the modes, signs, symptoms, and consequences of exposure. Verify that the proper atmospheric tests have been conducted and that procedures and equipment are in place before signing the confined space entry permit. Verify that the confined space entry permit is completed prior to each entry. Terminate the entry and cancel the permit when needed. Inform the trained Maintenance staff of the cancellation and reasons for cancellation. Verify that the means for summoning emergency personnel are available and operable in the event that an emergency occurs. Remove unauthorized individuals who entered or attempted to enter the confined space. IEA, Inc. Page 1 of 8
Bemidji Area Schools IEA Project #201510496 Management Plan for Confined Spaces November 2015 2.3 Confined Space Authorized Entrants Trained Maintenance staff have been designated and trained as Authorized Entrants for confined spaces in Bemidji Area Schools. The responsibilities of these individuals are as follows: Know and recognize the hazards that may be faced during entry, including modes, signs, symptoms, and consequences of exposure. Use and maintain proper PPE and other equipment needed as outlined by the management plan for confined space. Communicate with the attendant as necessary. Alert the attendant when hazardous conditions are detected, identified, or suspected. Exit the confined space immediately when: Ordered to do so by other entrants, the attendant, the confined space entry supervisor, or the identified contact person. Warning signs or symptoms are identified while in the area. Prohibited conditions exist or are identified by the entrant during work done in the area. An evacuation alarm on the 4-gas meter is activated. As other conditions dictate. 2.4 Confined Space Attendants Trained Maintenance staff have been designated and trained by Bemidji Area Schools to be attendants for confined space entry. Authorized attendants are responsible for the following: Know the hazards that may be faced during entry, including modes, signs, symptoms, and consequences of exposure. Maintain an accurate count of authorized entrants. Remain outside the confined space during entry operations until relieved by another attendant. Communicate with entrants and monitor activities inside and outside the confined space to determine if it is safe for authorized entrants to remain in the space. Order the authorized entrants to evacuate the space immediately under any of the following conditions: If the attendant detects a prohibited condition. If the attendant detects signs of hazard exposure in an authorized entrant. If the attendant detects a situation outside the confined space that could endanger the authorized entrants; or If the attendant cannot effectively and safely perform all duties required. Summon rescue and emergency personnel as soon as it is determined that entrants need assistance to escape from confined space hazards. Take the following actions when an unauthorized person(s) approach or enter a confined space while entry is underway: Warn the unauthorized person(s) that they must stay away from the confined space. Advise the unauthorized person(s) that they must exit immediately if they have entered the confined space. Inform the authorized entrants and the entry supervisor if an unauthorized person(s) has entered the confined spaces. Postpone duties that might interfere with the attendant s primary duty to monitor and protect the authorized entrants. 3.0 Workplace Confined Space Evaluations and Reclassification Steve Spindler, Safety, Warehouse and Purchasing Manager, is responsible for coordinating/conducting an evaluation of the district s facilities to determine if confined spaces are present. The assessment includes the location of each space, a brief description of the space, actual or potential health and safety hazards, and classification of the space (permit-required or non-permit-required). In addition, the spaces are assessed for the following hazards: IEA, Inc. Page 2 of 8
Bemidji Area Schools IEA Project #201510496 Management Plan for Confined Spaces November 2015 Thermal Hazards Hazards due to extremes in hot and cold temperatures. Engulfment Hazards Hazards from being overcome by material in a confined space (i.e., steam, gas, water, IDLH atmospheres). Noise Hazards Hazards that can affect hearing in emergency situations or two-way communications that may result directly to an injury suffered by an employee. Slick/Wet Surfaces Hazards that can increase the risks of slips, trips, or falls. These surfaces may also increase the risks and effects of shocks from electric tools, machinery, and/or circuitry. Falling Objects Hazards that exist from loose gravel, cement, tools, etc. that have the potential to cause harm to a worker in a confined space. Mechanical Equipment Hazards that may exist due to required machinery operating during an entry. Electrical Hazards Hazards that may exist from exposed wiring, power lines, or other faulty equipment. Fall Hazards Hazards that may be caused due to loose gravel, exposed wiring, or equipment left in an open area. Biological Hazards Hazards that exist from any personal injury that may occur in a confined space. When there are changes in the use of a non-permit confined space that may introduce new hazards, the space is re-evaluated and classified as a permit-required confined space where necessary. Reclassification is required for application of solvents, paint chemicals, or other materials that could potentially create a hazardous atmosphere in a confined space, and while performing welding, cutting, brazing, or soldering in those confined spaces with limited or no ventilation. The confined space assessments and reclassifications are maintained with the Management Plan for Confined Spaces in the Safety Manager s Office and each buildings Maintenance Office. 4.0 Identification of Confined Spaces Bemidji Area Schools identifies confined spaces by signs, placards, or symbols. These means of warning are printed in English, reading one of (but not necessarily limited to) the following: CAUTION: NON-PERMIT CONFINED SPACE - AUTHORIZED ENTRY ONLY DANGER: PERMIT-REQUIRED CONFINED SPACE - DO NOT ENTER 5.0 Entry Procedures for Permit-Required Confined Spaces Employees of Bemidji Area Schools are not allowed to enter permit-required confined spaces. The following entry procedures are implemented when a contractor is required to do work in a permitrequired confined space. The Safety, Warehouse and Purchasing Manager is notified prior to the entry of a permit required confined space. Only properly trained and authorized individuals are allowed to enter permit-required confined spaces. Entrants maintain contact with an attendant using two-way communication. The Confined Space Entry Permit is properly completed and signed by Safety, Warehouse and Purchasing Manager prior to entry. The permit contains the following information: The names of the individuals entering the permit-required confined space The date and time of entry The expiration date of the permit The results of atmospheric testing Date and signature of Safety, Warehouse and Purchasing Manager Prior to entry, the confined space is tested for oxygen content, flammable gases, and potential toxic air contaminants by a properly trained individual. High, middle, and low points of the area are tested to properly determine if the area is safe for entry. Continuous air monitoring is conducted throughout entry. Sampling procedures are follows: IEA, Inc. Page 3 of 8
Bemidji Area Schools IEA Project #201510496 Management Plan for Confined Spaces November 2015 The sampling device used is a 4-gas meter that can simultaneously test for oxygen, hydrogen sulfide, carbon monoxide, and combustible gas without manually switching. Calibration of all sampling equipment is relative to the oxygen content of the ambient air at the time of sampling. Calibration of the sampling device relative to the oxygen content is performed where the 20.9% natural content of oxygen in the air is most likely to occur. Note: Calibration of this equipment is not performed near a confined space opening. When sampling, the following levels must be obtained: The oxygen level is between 19.5% and 23.5%. The level of carbon monoxide (CO) is less than 35 ppm. The level of airborne hydrogen sulfide (H 2S) is below 10 parts per million (ppm). The concentrations of flammable gas, vapors, or mists, are below 10% of their lower flammability limits (LFL). The concentration of airborne combustible dust does not exceed 10% of the lower flammability limit (LFL). Note: An indication of this condition is if the dust obscures vision at a distance of five feet. Toxic air contaminants are less than the OSHA Permissible Exposure Limit (PEL) Note: If the substance does not have a PEL, the Threshold Limit Value (TLV) established by the American Conference of Governmental Industrial Hygienists (ACGIH) is used. Atmospheric concentrations of toxic substances known to be present in the confined space are below what is considered Immediately Dangerous to Life and Health (IDLH). Results of this test are posted outside the confined space on the Confined Space Entry Permit. If any of these atmospheric conditions are not met, entry into the confined space is not allowed. In order to allow entry and maintain a safe atmosphere, one or more of the following actions are taken to render the space safe for human occupancy: Isolation Precautions taken to prevent release of material and/or energy into the space. This can be achieved through disconnecting, lockout/tagout, or removal of incoming pipes or related energy sources. Ventilation Purging, inerting, flushing, or otherwise ventilating the space with fresh air. The replacement air will displace the contaminated air allowing for safe entry. This can be accomplished by removing ports and openings or by mechanically ventilating the vessel. Separation Where there is a possibility of external hazards, the space may require barricades to protect the entrants from falling objects or from unauthorized entry. Retrieval systems or methods are used whenever an authorized entrant enters a permit space, unless the equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. Personal protective equipment, including respirators, is provided to entrants as necessary for safe entry into the confined space and is used properly. Safety, Warehouse and Purchasing Manager must approve all PPE. Respirators are used in accordance with the district s Management Plan for Respiratory Protection. Employees of Bemidji Area Schools are prohibited from entering confined spaces with unknown atmospheres. A rescue team or emergency personnel with self-contained breathing apparatus (SCBA) must be present on-site and immediately available if entry is into an atmosphere that is actually or potentially immediately dangerous to life or health. An attendant is present outside the space throughout entry. Electrical equipment used in confined spaces is appropriate for the hazard and meet the requirements of the National Electric Code if a hazardous atmosphere is present. Any condition making removal of an entrance cover unsafe (i.e., pressure differential or physical obstacles) is eliminated before the cover is removed. When the cover has been removed, the opening(s) is promptly guarded to prevent an accidental fall into the opening and prevent objects from falling into the opening. IEA, Inc. Page 4 of 8
Bemidji Area Schools IEA Project #201510496 Management Plan for Confined Spaces November 2015 Where applicable, appropriate vehicle and pedestrian barriers are used to protect workers. Metal ladders are not used under any circumstances in permit-required confined spaces. Any use of chemicals or welding, soldering, or cutting operations are pre-approved by the Safety, Warehouse and Purchasing Manager prior to entry. 6.0 Contractor Guidelines Contractors hired by the district are informed that the workplace contains permit spaces and that permit space entry is allowed only through compliance with a permit space program meeting OSHA requirements. The contractor is provided a copy of the permit space assessment (including identified hazards). The contractor is debriefed at the conclusion of the entry operations regarding the permit space program followed and regarding any hazards confronted or created in permit spaces during entry operations. 7.0 Non-Permit-Required Confined Spaces In order to protect the safety and health of employees associated with non-permit-required confined space entry, employees (and supervisors) obtain and use the proper PPE, tools, and other equipment necessary to perform the job. Atmospheric testing of a non-permit-required confined space is not required; however, testing the atmosphere for toxic gases and oxygen deficiency prior to entering the confined space is recommended if a properly calibrated 4-gas meter is available. An attendant is not required for entry into a non-permit-required confined space; however, the district s employees inform other personnel when entering and exiting a non-permit-required confined space and utilize two-way radios as appropriate. Other district safety programs (i.e., personal protective and respiratory protection) still apply to entry into non-permit-required confined spaces. Boiler Entry Prior to entering the confined space of a boiler, the boiler is locked out at each hazardous energy source. In addition, the following occurs before entry: The interior temperature of the confined space closely equals the ambient temperature outside that space. Hazardous materials (solids and liquids) inside the work area are removed from the vessel. Lines leading into and away from the vessel are blanked, blinded, and/or double blocked and bled. 8.0 Ventilation of Confined Spaces If a confined space is found to contain a hazardous atmosphere, forced air ventilation may be provided for a period of time in order to bring the air quality within acceptable limits. Once the determined ventilation period expires, employees monitor the confined space. If sampling shows that a hazard still exists, additional ventilation and sampling may be required. If the hazard still exists after repeated ventilation, the confined space is not entered. Note: Forced air ventilation is not used in lieu of monitoring. Consideration is also given to the possibility of static discharge that could be a source of ignition. Whenever ventilation is used, employees: Keep the blower controls at least ten feet from the confined space, and out of the wind or downwind from the entrance of the confined space. Use a ventilation blower that is designed to be intrinsically safe, if the possibility of an explosive atmosphere could exist. Verify that the exhaust systems are designed and placed so that they protect employees in the surrounding area from being contaminated. Verify that the ventilation system is fully operational. Take measures to prevent contaminated air from being re-circulated into the confined space. IEA, Inc. Page 5 of 8
Bemidji Area Schools IEA Project #201510496 Management Plan for Confined Spaces November 2015 Purge the ventilation hose outlet for at least one minute (at street level if possible) before inserting the hose into the confined space. Maintain continuous local ventilation when toxic atmospheres are being produced as part of a work procedure (i.e., welding, painting, or cleaning operations). 9.0 Equipment Used In Confined Spaces When a confined space entry requires the use of equipment and tools inside the space, this equipment is inspected prior to use and meet the following requirements: Hand tools are in good repair and kept clean. Portable electric tools, equipment, and lighting are listed Class I, Division I, and Group D. All grounds are checked and in good working condition. Note: Ground fault protectors are used whenever possible to protect employees from electrical shock when working in damp or wet locations. Electrical cords, tools, and equipment are constructed of a heavy-duty, double insulated cord, and equipped with a three-prong plug. No two prong plugs are acceptable unless under special circumstances and approved by Bemidji Area Schools. Electrical cords, tools, and equipment are visually inspected for defects before entering a confined space. Defects include cut or frayed cords, missing ground plugs, and taped cords. If equipment is found defective, it is removed, replaced, and marked Do Not Use - Out of Service before any employee enters a confined space. It is prohibited to bring compressed gas cylinders into a confined space. The only exemption from this rule is the cylinders that are considered part of SCBA or resuscitation equipment. Ladders to be used in confined spaces are constructed of plastic or fiberglass and are adequately secured or of a permanent type which provides the same degree of safety. Permanent ladders used in confined spaces are inspected for rust or corrosion and are repaired or replaced if necessary. All equipment that may be used in a flammable atmosphere is approved as either explosion proof or intrinsically safe for the atmosphere and is approved by a recognized testing laboratory (e.g., UL, FM). 10.0 Emergency Service Confined Space Rescue Although district employees do not enter confined spaces, we have developed rescue procedures in the event of an emergency. The district has: Evaluated prospective rescuer s ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified. Evaluated prospective rescue service s ability, in terms of proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit space identified. Selected rescue teams or services that have the capacity to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified, and are equipped for and proficient in performing the needed rescue services. Informed rescue teams or services of the hazards they may confront when called on to perform rescue at the site. Provided rescue teams or services access to all permit spaces from which rescue may be necessary so that the rescue service can develop and implement appropriate rescue plans and practice rescue operations. Note: Appendix F of the OSHA 29 CFR 1910.146 Standard contains examples of criteria that employers can use in evaluating prospective rescuers. IEA, Inc. Page 6 of 8
Bemidji Area Schools IEA Project #201510496 Management Plan for Confined Spaces November 2015 The Bemidji Fire Department has agreed to work as rescue teams in the event of a confined space emergency. The direct phone number to the Bemidji Fire Department is 218-751-8001. In the event of an emergency, the school will dial 911. The call will be directed to the appropriate fire department. Each department has been trained on confined space procedures and retains a copy of the district s confined space inventory. The fire departments rely on mutual aid in the event of an emergency that cannot be handled by one or more of the fire departments. 11.0 Employee Training Employees who are required to supervise a confined space entry, enter a confined space, or serve as an attendant are trained and properly equipped to recognize, understand, and control hazards that may be encountered during confined space entry. Training is documented by certification, including the employee s name, signature of trainer, and training dates. Certification is available for review by employees or other personnel. Training includes: Associated safety and health hazards of confined space entry Duties of entrants and attendants Air monitoring Respiratory protection Emergency rescue procedures Lockout isolation procedures Use of PPE Use of equipment such as a 4-gas meter, ventilation, communication devices, or lighting Training is provided to affected employees: Before the employee is first assigned to confined space duties Before there is a change in assigned duties Whenever there is change in confined space operations that presents a hazard about which the employee has not been previously trained When there are deviations or inadequacies in employee knowledge or use of procedures 12.0 Recordkeeping The following records are maintained in relation to this program: Employee Training Records this includes dates and names of attendees. These records are held at least three years. These training records are maintained at the Safety, Warehouse and Purchasing Manager s Office. Confined Space Entry Equipment Inspections this includes dates, results, and corrective actions taken if necessary. These records are held for the lifetime of the equipment. Monitoring Equipment Calibration/Service Reports this indicates the calibration dates and any service conducted by the manufacturer. These records are maintained for the lifetime of the equipment. Confined Space Permits this includes the names of the individuals entering the confined space, dates and time of entry, expiration date of the permit, results of the atmospheric testing, and the signature of the Safety, Warehouse and Purchasing Manager. These records are maintained for a period of one year. IEA, Inc. Page 7 of 8
Bemidji Area Schools IEA Project #201510496 Management Plan for Confined Spaces November 2015 13.0 Annual Review The Safety, Warehouse and Purchasing Manager reviews the Confined Space Program at least annually using cancelled Confined Space Permits and other available information and records in order to determine if: Changes should be made to improve the program s overall effectiveness Additional hazards have been identified within a given space Additional measures should be taken to protect the entrants Additional confined spaces should be included within the program Some locations can be removed from the program. IEA, Inc. Page 8 of 8
Appendix A Confined Space Assessments and Inventory
Appendix B Confined Space Entry Permit (for Contractors)
PERMIT REQUIRED CONFINED SPACE ENTRY PERMIT Building Name: Activity to be Conducted: Permit Prepared by: Entry Date: Confined Space: Signature: Expiration Date: Authorized Entrant Authorized Attendant Time of Entry Time of Exit Preparation and Isolation Emergency procedures in place? Yes No NA Pumps or lines blocked, blanked, or disconnected? Yes No NA Mechanical ventilation? Yes No NA Equipment lockout/tagged out? Yes No NA Hot Work permit required? Yes No NA Equipment Calibrated 4-gas meter Yes No NA Safety harness/lifelines Yes No NA Communication equipment Yes No NA Proper PPE Yes No NA Mechanical retrieval devices Yes No NA Atmospheric Check (conducted prior to entry and periodically throughout entry) Time of Check Oxygen (19.5-23.5%) Combustible (<10% CH4) Toxic (<10% H2S) Carbon Monoxide (<35ppm) Name of Tester PRIOR TO ENTRY % %LEL ppm ppm % %LEL ppm ppm % %LEL ppm ppm AUTHORIZATION BY ENTRY SUPERVISOR OR PROGRAM COORDINATOR I have reviewed the work authorized by this permit and the information contained herein and written instructions and safety procedures have been reviewed. This permit is not valid unless all appropriate items are completed and understood. Print Name Signature Date POST THIS PERMIT AT THE ENTRANCE TO THE CONFINED SPACE DURING ENTRY Permit Cancelled by: Date: Time:
Appendix C Reclassification Records
CONFINED SPACE RECLASSIFICATION RECORD District: Building: Type of Space: Location: Previous Classification: New Classification: Reason for Reclassification: AUTHORIZATION BY ENTRY SUPERVISOR OR PROGRAM COORDINATOR Print Name Signature Date