International Environmental Health and Safety (IEHS) Section 16 Confined Space Entry Program 16.1 Objective The Confined Space Entry Program has been developed to protect IEHS project employees working on site, under contract to IEHS, and mandatory safety requirements for entering, working in, and exiting confined or enclosed spaces. It is IEHS s position to only enter confined or enclosed spaces during the construction phase of a project that is listed as non permit confined space in nature. When feasible, where hazards exist to a degree that would necessitate listing a confined space as permit required, IEHS will address the identified hazards through engineering controls in order to elevate and/or reduce the hazards to a level that would allow the space to be downgraded to a non permit confined space. Please note that the requirements and information within this program are intended to address the hazards associated with confined space entry. In addressing the overall work hazards represented by a given project scope, the project team should also reference all other applicable IEHS H&S programs. The following information provides direction and guidance to Site Safety Team for implementation of IEHS s Confined Space Entry Program. 16.2 Roles and Responsibilities Competent Person The competent person will work in concert with the Site Safety Team to successfully implement the requirements of this program including the requirements listed below: Approve confined space entries using the Confined Space Entry Permit (Figure 17 1). Provide on site guidance for confined space entry issues and questions. Observe the implementation of confined space entry and perform monthly audits regarding Confined Space Entry Program implementation. 16-1
16.3 General Requirements Inspection and Evaluation Work areas will be inspected by the Site Safety Team and/or listed competent person(s) on an ongoing basis and evaluated to determine at what stages the work area is to be considered one of the following types of spaces: Non confined space Non permit confined space Permit required confined spaces The inspection is the responsibility of the designated Site Safety Team or other designated (subcontractor s) competent person(s) and will be conducted during monthly safety inspections/audits. All recognized hazards will be listed and evaluated. Conditions that prohibit entry to a confined space will be evaluated and listed on the entry permit. Established lists of permit required and non permit confined spaces shall be determined during project start up and evaluated periodically during the monthly safety inspections/audits. These lists will be provided to on site employees (including subcontractors) and updates to the listing will be provided by the Site Safety Team during weekly safety meetings and daily PTP reviews, as appropriate. Non permit confined space procedures will include routine documented atmospheric monitoring when work is being performed in the non permit confined space. All employees required to enter into a confined or enclosed spaces shall be instructed as to the nature of the hazards involved, the necessary precautions to be taken, and in the use of PPE and emergency equipment required. The employee shall comply with any specific regulations that apply to work in dangerous or potentially dangerous areas. Confined Space Entry The Site Safety Team, competent person(s), and subcontractor s safety representatives shall assure that all applicable procedures of this program have been fully implemented prior to any confined space entry. Permit-Required Confined Space Entry Personnel Requirements/Duties All personnel, issued permits to enter confined spaces, must know the hazards they may face, be trained to recognize signs or symptoms of exposure, and understand the consequence of exposure to hazards. Authorized Entrants Authorized entrants must know how to: use required equipment; communicate with attendants; alert attendants when warning signs or other hazardous conditions exist; and 16-2
exit as quickly as possible whenever ordered or alerted (by alarm, warning sign or prohibited condition) to do so. Attendants Attendants must know the hazards of a confined space and be aware of potential exposures. Attendants must know how to: Check permits of authorized entrants; Prevent entry by those without a permit; Maintain a continuous count of those in a confined space, by utilizing a sign in and sign out form; Monitor activity in the confined space; Perform intermittent or continuous air monitoring; Remain outside the confined space until relieved; and Be trained and certified in CPR/First Aid. If necessary, an attendant will know how to: order all employees to exit a confined space; contact rescuer team; and perform non entry rescue. Attendants may not perform any duty that will interfere with the duties listed above. Entry Supervisor Entry supervisors must know the hazards of confined spaces and must verify that all tests have been conducted and all procedures and equipment are in place before endorsing a permit. They must also verify that rescue services are available and that the means for summoning them are operable. Entry supervisors will know how to: understand confined space hazards; verify emergency response plans; train attendants and entrants; evaluate applicable MSDSs; review and approve permits; implement entry permit; authorize entry; ensure entry operations are consistent with entry permit; and close and cancel permits. 16-3
Rescue Operations Rescue services must be available for all permit required confined space entries, except for vertical entries where non entry rescue offers the safest approach. Rescue teams can be comprised of on site or outside personnel; however, they must be able to meet and comply with the requirements of this program. Rescue teams must be made aware of the nature and type of hazards within permit spaces and must be provided access to the permit spaces prior to work being performed in order to develop rescue plans and practice rescues. The Site Safety Team and/or listed competent person(s) must contact rescue teams prior to permitting entry into a permit required confined space. Rescue services will be called in the event of any emergency involving confined space and must have training equivalent to the potential situations in which they may be required to assist. The entry supervisor will be responsible for contacting the rescue team. If outside services are used as primary or secondary rescue, the entry supervisor shall communicate with the rescue team to ensure that they are aware of the ongoing entry. These steps shall be documented on the Confined Space Entry Permit. The minimum requirements for rescue teams are as follows: 1. Rescuers are to be qualified as authorized entrants for the confined space in which work is being performed. 2. Rescue personnel will practice making permit space rescues at least once every 12 months, by means of simulated rescue operations from the actual permit spaces or from representative permit spaces. Representative permit spaces must simulate the actual permit space being entered, with respect to opening size, configuration, and accessibility. 3. Rescue personnel will be trained and certified in First Aid/CPR. 4. Rescue personnel are to be equipped with, and trained to use, PPE and rescue equipment necessary to enable them to enter and perform rescue operations in the permit required confined space. Atmospheric Testing Methods of Testing Atmospheric testing is required for two distinct purposes: evaluation of the hazards of the permit space and verification that acceptable conditions for entry into that space exist. Barring ventilation methods commonly used (i.e., airing out electrical vaults prior to entry), confined spaces that have a reasonable potential for hazardous atmospheres should, at a minimum, be tested for oxygen content prior to entry. Evaluation Testing The atmosphere of a confined space should be analyzed using the proper equipment to identify and evaluate any hazardous atmospheres that may exist or arise. 16-4
Evaluation of this data should be performed by a qualified individual. Superintendents, foremen, safety supervisors, or anyone else using testing instruments are to have documented training for the specific instruments that they are using. Verification Testing The atmosphere of a permit space that has a reasonable potential to contain a hazardous atmosphere should be periodically tested. Testing should be done with the equipment specified on the entry permit to determine that residual concentrations at the time of testing and entry are within the range of acceptable entry conditions. Results of testing should be recorded on the permit in the space provided. All entrants or their representatives must be given an opportunity to participate in and review calibrated air monitoring data before entry. If the confined space is vacated for any significant period of time (>30 minutes) or if entry is not initiated within 15 minutes of issuance of the permit, the atmosphere of the confined space shall be tested or re tested before entry is permitted. Additional monitoring may be requested at any time if there is reason to believe conditions have changed in the confined space. Duration of Testing Values for each atmospheric parameter should be measured for at least the minimum response time of the test instrument specified by the manufacturer. Testing Stratified Atmospheres When monitoring for entries involving a descent or ascent into atmospheres that may be stratified, the atmospheric envelope should be tested at a distance of approximately four feet in the direction of travel and to each side. If a sampling probe is used, the entrant s rate of progress should be slowed to accommodate the sampling speed and detector response. Stratified testing should be performed during the work since activities in the confined space could change gas concentrations at varying levels during work procedures. Tests should be performed at the top, middle, and bottom sections of entry space due to the different specific gravities of gases/vapors. An exception to this is wind turbine towers where the natural chimney effect virtually eliminates stratified atmospheres. However, if at any time during tower climbing activities the atmosphere becomes suspect, the climb will be suspended until atmospheric testing can be performed. Order of Testing A test for oxygen is performed first because combustible gas meters are oxygen dependent and will not provide reliable readings in an oxygen deficient atmosphere. If the confined space is suspected of having a corrosive atmosphere, the ph of the air may be tested prior to oxygen. Combustible gases are tested for next because the threat of fire or explosion is both more immediate and more life threatening, in most cases, than that of exposure to toxic gases and vapors. If tests for toxic gases and vapors are necessary, they are performed last. 16-5
Ventilation Systems There are two kinds of forced air or mechanical ventilation: 1. Local exhaust ventilation 2. General ventilation (also known as dilution ventilation) Local exhaust ventilation captures contaminants at the point of origin and removes them. It is the best way to control flammable and toxic materials produced at a single point. Local exhaust ventilation does not work well when contaminants are widely dispersed, or when the location or shape of the confined space makes it difficult to use. In this case, general ventilation is more suitable. General ventilation flushes the atmosphere by supplying and exhausting large volumes of air. It does not effectively reduce the amount of contaminants released, so there are limits on when it can be used. The ideal use for general ventilation is as follows: To provide oxygen to the confined space To control low concentrations of materials that are not highly toxic When entrants are not too close to the contaminant source When the concentrations of contaminants are low When the contaminants are produced at a fairly uniform rate General ventilation can be separated into two types: exhaust and supply ventilation. Drawing air out is better when the atmosphere within the confined space could be flammable or toxic. Blowing air in can spread contaminants within the confined space, especially if the contaminants are introduced outside of the confined space and sucked in. Ventilation Safety The following safety principles should be followed when ventilating: Never use pure oxygen for ventilation or purging. Always ground electrical ventilation equipment. Explosion proof equipment should always be used. Exhaust ventilation should always be located so that its exhaust will not be drawn back into the confined space. Exhaust ventilation should always be located so that it will be dispersed quickly and will not have any adverse impact on others. Exhausted contaminants should be filtered, if possible, to trap airborne contaminants. 16-6
Never allow flammable materials to be located near exhaust systems. Use equipment that is sufficiently sized for the space to be ventilated. Any time there is the possibility of toxic or flammable gases being sucked into a confined space in an existing process area, an attendant should be stationed outside the confined space. Ensure that all exhaust from vehicles is pointed away from entry point as to prevent fumes from traveling into confined space. Personal Protective Equipment The entry supervisor will determine the necessary PPE for entering the permit required confined space safely. At a minimum, each entrant is to wear: Basic safety equipment (i.e., hard hat, safety glasses, clothing, boots, gloves, etc.) Hearing protection as necessary Full body harness with D ring located at the center of entrant s back and life line attached Respirator, as required on entry permit for hazardous atmospheres Miscellaneous equipment (i.e., communication equipment), as required on entry permit At least one air monitor will be carried by the employee performing work inside a permitrequired confined space, as conditions may change at any time With the aid of the attendant, the entry supervisor will enforce the use of the proper PPE. Permit-required Confined Space Entry Permits Entry permits, to be completed by the entry supervisor, must include the following: Identification of the space and location Purpose of entry Date and duration of permit not to exceed one shift List of authorized entrants Names of current attendants and entry supervisor List of hazards in the permit space List of measures to isolate permit space and eliminate/control hazards The acceptable entry conditions Results of tests initialed by the employee(s) performing test: initially, every 30 minutes during work, and at the conclusion of the entry Identification of rescue and emergency services and methods of summoning Rescue and emergency services and means to summon 16-7
Communication procedures for attendants/entrants Required equipment (i.e., respirators, communication devices, alarm, etc.) Any additional permits (e.g., hot work or LOTO) 16.4 Training All project employees will receive training during site specific orientation regarding IEHS s requirements involving work with confined space entry hazards. Additional training for employees who will implement confined space entry procedures will be provided during site specific H&S training. This training must include both initial and refresher training. Refresher training is necessary when duties change, hazards change, or evaluation determines inadequacies in an employee s knowledge. Training on IEHS s Fall Protection Program, LOTO Program, and PPE Program is also required for employees involved with confined space entry where these hazards are present. Rescue equipment training is required every 12 months for personnel working in confined spaces using the actual rescue equipment in an emergency. The entry supervisor will ensure that all persons involved with the confined space entry will be trained and tested as necessary. He/She is to give training that ensures understanding, knowledge, and skills necessary for the safe performance of their assigned duties. Training will be given at the following times: Prior to any new employee being assigned confined space duties; Before there is a change in assigned duties; and Whenever the entry supervisor has reason to believe that there are deviations from the permit space entry procedures or that there are inadequacies in the employee s knowledge or use of these procedures. The training requirements for entrants will include: Hazard recognition be aware of hazards that may be present during entry be familiar with symptoms of overexposure to hazards be aware of health effects of overexposure PPE be aware of requirements for PPE know proper procedures for using PPE External hazards be aware of external barriers required to protect entrants from external hazards be familiar with the proper use of those barriers 16-8
The training requirements for attendants will include the following elements: Review of the confined space permit Hazard recognition recognize potential physical and chemical hazards in and outside the permit space recognize signs and symptoms of overexposure of hazards to entrants Equipment knowledge be aware of rescue and monitoring equipment present (if any) and how to use equipment Rescue procedures be familiar with non entry rescue procedures and contacts to be made in case of emergency If also serving as an entrant or attendant, entry supervisors will be subject to the same training requirements as either of those groups. This training will be provided by the Site Safety Team. Permit Review and Approval All Confined Space Entry Permits shall be inspected and approved by the Site Safety Team, listed competent person(s), and/or subcontractor H&S representative prior to commencement of the work and cancelled at the end of a shift. Cancelled Confined Space Entry Permits shall be maintained in the project file for a minimum of one year. No work involving permit required confined space entry shall be permitted until the permit is completed and implemented to the satisfaction of the Site Safety Team, listed competent person(s), and/or subcontractor H&S representative. Subcontractors shall ensure that their H&S representative and/or competent person(s) provide this approval for their Confined Space Entry Permits, with documentation provided to the Site Safety Team. A review of entry operations and procedures will occur any time there is reason to believe employees are not adequately protected under this program. Revisions to this program will be made prior to subsequent entries if deficiencies are found to exist. 16.5 Audits and Inspections Monthly audits of canceled confined space entry permits, designated confined spaces, confined space entry procedures and compliance with established procedures will be conducted by the Site Safety Team, competent person(s), subcontractor s H&S representative, or their designees, as outlined within IEHS s H&S Inspection/Audit Program. These audits shall be documented in the project files and deficiencies shall have timely corrective action measures defined. The auditor will be responsible for ensuring that corrective measures are met within the established time frame and must report any non compliance to the PM for immediate follow up including, but not limited to, disciplinary action as outlined in IEHS s H&S Discipline Program for the affected individuals. 16-9
16.6 Documentation Confined Space Entry Permits shall be effective for no longer than one work shift. Separate permits will be completed for work during subsequent shifts, as necessary. All confined space entry training, permits, implementation audits, and subcontractors documentation of the same shall be maintained by the Site Safety Team in the project file on site. All documentation generated, as a result of training and Confined Space Entry Permit creation, shall be maintained at the project site by the Site Safety Team throughout the life of the contract and transmitted to the project files for storage when the job has been completed. 16-10
1. Project Name: Figure 16-1 Confined Space Entry Permit 2. Date of Entry: 3. Time: 4. Type of Space: 5. Location: 6. Subcontractor: 7. Type of Work Performed: 8. Entry Supervisor: 9. Entrants: 10. Attendant: 11. Special Hazards Lack of oxygen Flammable/explosive gases Toxic vapors Chemical contact Electrical shock Mechanical exposure Temperature Fall potentials Engulfment YES NO INITIALS 12. Employees have been instructed in confined space entry procedures and instructed in special hazards and precautions to be taken in this specific entry. 13. Cleansing of hazardous material by: Water Steam Other: 14. Input isolation (identify line and method isolated). 15. Lockouts: Electrical Mechanical 16. Access to entries have posted warnings, are well barricaded, and have covers secured in open positions. 16-11
17. Atmospheric Test Verification: Continuous (record every two hours) Yes No TEST LEVEL TIME READING TIME READING Oxygen 19.5% to 23.5% Lower flammable limit (LFL) Under 10% Carbon Monoxide (CO) Less than 35 ppm Hydrogen Sulfide Under 7 ppm Other: 18. Atmospheric Tester (Name): Instrument(s) used (model and serial number) 19. Type of Ventilation: 20. Personal Protection: YES NO Safety belt/harness Respiratory protection Hard hat Eye protection Hearing protection Gloves Impervious clothing 21. Safety Equipment: YES NO Emergency entry lifelines Portable 12-volt lighting or protected lighting Ground fault electrical protection Non-sparking tools Ladders, scaffolds, fall protection Emergency response Air horn Radio Telephone Pull Box 16-12
22. Special Instructions: 23. Rescue Procedures: 24. We have reviewed the work authorized by this permit and the information contained herein. Written instructions and safety procedures have been received and are understood. Entry cannot be approved and this permit is not valid unless all appropriate items are completed. Entry Supervisor: Attendant: Site HSM/Competent Person: Site HSM/Competent Person: Permit Completed SIGNATURES Cancelled DATE A copy of the permit is to be retained by IEHS. The original permit must be with the crew entering the confined space or entry will not be allowed or, if operation has started, the employee(s) will be removed from the confined space and work will be stopped until the permit is in their possession. The original permit is to be returned to IEHS after completion of work or cancellation of the permit. 16-13
Instructions for Completing the Confined Space Entry Permit All sections and questions need to be addressed, but if a particular section and/or questions does not apply, simply mark it NA (not applicable). The entry supervisor will complete each line of the permit as described below: LINE DESCRIPTION 1. Fill in the name of the project. 2. and 3. Fill in the (1) actual work date and the (2) anticipated starting time and finishing time. Should the work activity in the confined space take a longer period of time than originally estimated, an extension of time will have to be authorized by the party s signatory to the original permit. 4. Describe the confined space that will be entered such as boiler, fuel storage tank (10,000 gallon), electrical vault, etc. 5. Identify the exact location on the site of the confined space. 6. The name of the subcontractor who has the permit and who will performing the work in the confined space. 7. Brief description of what activity is going to take place in the confined space (e.g., painting, coating, cutting/welding etc.) 8. The name of the entry supervisor. 9. The names of the specific employees who will be working inside the confined space. 10. The names of the specific employee(s) who will be assisting the operation and acting as an attendant or standby outside of the confined space. 11. This is a checklist of special hazards and, where necessary, the initials of the employee indicating whether or not a specific hazard is present should be shown. As an example, the electrical superintendent should verify that there is no electrical power hooked up to that specific confined space and should then initial the list. 12. This is to verify, by the initials of the entry supervisor, that individuals entering the confined space, as well as those standing by, have been trained. 13. If there was such material in the confined space, how was it cleaned and whose responsibility was it to see that it was properly cleaned? If no such material existed in this particular confined space, indicate with NA and the initials of the competent person to make that determination. 14. Are there any activated process lines into the confined space? If so, they need to be isolated and provisions need to be made to shut them down. 15. Are energized electrical circuits and/or mechanical systems locked out and tagged out in accordance with the procedures set forth in the LOTO supplement? 16. The opening to the confined space needs to be secure in the open position, with barricades and signs posted warning people that only those with the entry permit are allowed to enter. 17. Identify whether the monitoring is continuous or periodic. Fill in the testing results and the times the confined space was tested. For continuous testing, write down the instrument records a minimum of every two hours. Periodic testing requires a minimum of three readings per shift. Identify the testing results of sampling taken before entry. Identify whether the atmosphere is sufficient for performing cold work or hot work. 18. Identify type and serial number of all sampling equipment used for entry into the confined space. 16-14
LINE DESCRIPTION 19. Ventilation must be provided in accordance with the readings taken. Since the ventilation may take many forms, it is requested that the type used for this particular space be noted on the checklist. 20. In this area, it is necessary to list the personal protective items issued to each member of the entry team and each member of the stand-by team. 21. This area is for listing all safety equipment other than the personal protective items listed above. Be sure that the stand-by team is equally prepared to enter the confined space. 22. Identify to all personnel involved with the confined space entry any special precautions, techniques, or procedures that must be used or followed. Identify any additional permits that are required for entry. 23. Rescue teams must be made aware of the nature and type of hazards within confined spaces and must be provided access prior to work being performed in order to develop rescue plans and practice rescues. Describe rescue procedure for this confined space. 24. The signatures of the entry supervisor and the site HSM/competent person shall be on the permit. Alternates may be designated to sign for those that are absent from the site; however, the alternate designated for the normal safety representative must be the employee designated to be responsible for those duties when the normal safety representative is off site, and must be a competent person. 16-15