PERMIT-REQUIRED CONFINED SPACE PROGRAM
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1 PERMIT-REQUIRED CONFINED SPACE PROGRAM 1.0 PURPOSE The Indiana University (IU) is to: 1.1 Inform employees of the hazards associated with working in confined spaces 1.2 Differentiate between confined spaces and permit-required confined spaces 1.3 Provide employees information as to the location of confined spaces and permit-required confined spaces on all campuses 1.4 Provide employees with basic concepts and procedures for working in permit-required confined spaces 1.5 Comply with permit-required confined spaces regulations issued by Indiana Occupational Safety and Health Association (IOSHA) and other state and federal agencies 2.0 REGULATORY REFERENCES IOSHA Standard 29 CFR SCOPE This document is intended as a master document that addresses regulatory requirements. Details specific to implementing the program for a specific department or job can be added by the user in the appendices of the program. This program is applicable to all Indiana University employees. The program differentiates between confined spaces and permit-required confined spaces (PRCS). Because of higher risks associated with permit-required confined spaces the emphasis of the program lies here. 4.0 ELEMENTS OF THE PROGRAM Confined spaces are defined as a work area which: 4.1 Has limited or restricted means for entry and exit 4.2 Is large enough for employees to enter and perform work 4.3 Is not designed for continuous occupancy Permit-required confined spaces also: 4.4 Contain or could contain hazardous atmospheres 4.5 Can contain materials that has the potential for engulfing the entrant 4.6 Can have inwardly converging walls 4.7 Has any other recognized safety or health hazards Workers entering a PRCS without adequate knowledge and preparation are at risk for serious injury or death associated with atmospheric hazards or physical hazards. Atmospheric hazards include: 4.8 Oxygen levels above or below limits 4.9 Presence of toxic or flammable gases 4.10 Airborne combustible dusts 4.11 Any other Immediately Dangerous to Life or Health (IDLH) atmosphere 1
2 Physical hazards include: 4.12 Uncontrolled sources of electricity 4.13 Slip, trip, fall hazards 4.14 Mechanical equipment 4.15 Water 4.16 Heat or cold 4.17 Other Program elements of the Indiana University PRCS Program include: 4.18 A description of the process used in planning the PRCS entry 4.19 A description of IU s PRCS entry team, their roles and responsibilities 4.20 IOSHA s Hazard Identification flow chart 4.21 PRCS entry procedure 4.22 Confined space job briefing and planning checklist 4.23 Alternate entry procedures 4.24 Equipment and safety equipment checklists 4.25 Forced air ventilation procedures Detailed roles and responsibilities for members of the PRCS entry team are described in Section 5.0. The IOSHA hazard identification flow chart and examples of each procedure and checklist can be found in Appendix C1 of this document The Process Planning the Entry Determine the reason for entry into the PRCS Detail all work to be done a. People skills required b. Time required c. Equipment, supplies required Identify all known and potential hazards a. Determine how the hazards will be handled b. Consider contingencies and accidents Perform preparatory air monitoring and atmospheric testing Complete the Entry Permit a. Include special conditions fall potential, hot work, LOTO, etc. b. Include special equipment and special procedures The Entry Process Equipment set-up Atmospheric monitoring Monitoring the entrant Handling emergencies Performing required work 2
3 The Exit Remove all equipment Account for all personnel Close out entry permit Handling Emergencies Identify potential emergencies wherever possible Include those emergencies in the planning process Recognize problems early 5.0 ADMISTRATION/COMPLIANCE/RESPONSIBILITIES Indiana University s PRCS is administered through the Office of Environmental, Health, and Safety Management (EHS). This includes maintenance of the written program, maintaining the database, identifying confined spaces on each campus, evaluating confined spaces for permitrequirements, and training personnel who are members of the PRCS entry teams. Confined space entries are performed by Physical Plant personnel. The Physical Plant Administration is responsible for assigning personnel to the permit-required space entry teams, making certain that all necessary equipment and supplies are available, ensuring all team members are appropriately trained and briefed about the entry. The Physical Plant Administration has the ultimate responsibility for all workers entering a PRCS. Physical Plant personnel assigned to the PRCS entry team fall into three groups: the Authorized Attendant, the Authorized Entrant, and the Entry Supervisor. Their specific responsibilities are presented below. The PRCS entry team includes, at a minimum, the following: 5.1 The Authorized Entrant(s) Must know the hazards of the space, possible means of exposure, signs and symptoms of exposure, and consequences of exposure Must use appropriate personal protective equipment Must maintain communication with the attendant to enable them to monitor the entrant s status and to alert the entrant for the need for evacuation if necessary Must be able to perform assigned tasks Know how to use atmospheric monitoring equipment Is required to exit the PRCS as soon as possible when ordered to do so by the attendant, recognizes warning signs or symptoms of hazard exposure when a prohibited condition exists, when an automatic alarm is sounded, or when the task is completed Must alert the attendant when a prohibited condition exists, or warning signs or symptoms of exposure to a hazard exist 3
4 5.2 The Authorized Attendant(s) Must remain immediately outside the PRCS during entry unless relieved by another qualified and authorized attendant Perform non-entry rescues if specified in the entry permit and planning process Know existing and potential hazards, including the mode of exposure, signs and symptoms of exposure and consequences of exposure Maintain communication and keep an accurate accounting of those entering the PRCS Order evacuation of the PRCS when a prohibited condition exists: any worker within the PRCS showing signs of hazard exposure, an emergency outside the PRCS arises, or the attendant cannot safely perform his required duties Summon rescue and other services during an emergency Ensure that unauthorized people stay away from the PRCS Perform no other duties that interfere with the attendant s primary duties 5.3 The Entry Supervisor Must approve and sign the entry permit Know the hazards of the PRCS, including possible means of exposure, signs of exposure to the hazards, and the consequences of exposure Verify the conditions specified in the entry permit before allowing entry Terminate entry and cancel permits when the entry operations are completed or new conditions exist Verify emergency planning Take appropriate means to remove unauthorized personnel Ensure that entry operations remain consistent with the entry permit. 6.0 REQUIRED TRAINING AND RECORDKEEPING 6.1 Confined space awareness training will be provided to all Physical Plant employees upon hire and periodically thereafter. Awareness training will include: Definitions and descriptions of confined spaces and permit-required confined spaces Hazards associated with confined spaces Examples of many confined spaces on the IU campuses Warning signage Clear instructions that only trained personnel may enter a PRCS Contact information for PRCS-trained employees 6.2 Designated Entry Team Training will be provided for a select group of IU employees. They will be fully trained in PRCS and will be the designated entry teams for all PRCS work. This training will be provided before said employees become a part of the PRCS entry teams and periodically thereafter. Team members will be trained together. This training will include: Confined space awareness training with in-depth discussion of hazards Identification of PRCSs at IU Roles and responsibilities of entry team members Use of confined space entry equipment Use of air monitoring equipment 4
5 6.2.6 Respiratory protection The PRCS entry process Fall protection Non-entry rescue Table-top or on-site scenarios A record of all PRCS entries at IU will be kept. The record includes the entry permit air monitoring records. It will also include a description of any exceptions to the permit and accident records when applicable. Copies will be forwarded to EHS. 5
6 APPENDIX A: DEFINITIONS Indiana University Office of Environmental, Health, and Safety Management Acceptable Entry Conditions: The conditions that must exist in a PRCS to allow entry and to ensure the entry team can safely enter and work within the space. Attendant: The entry team member stationed outside the PRCS who monitors the entrants and performs all assigned duties. Authorized Entrant: The entry team member authorized to enter and work in the PRCS. Confined Space: A space that: Is large enough and so configured that an employee can bodily enter and perform assigned work Has limited or restricted means for entry or exit Is not designated for continuous occupancy Do Not Enter: A label used to indicate confined spaces that shall not be entered by other than trained members of the PRCS entry team. Emergency: Any occurrence, including any failure of hazard control or monitoring equipment, or an event internal or external to the PRCS that could endanger entrants. Engulfment: The surrounding and effective capture of a person by a liquid or finely divided solid substance that can cause death by asphyxiation or crushing. Entry: The actions of a person passing through the entry portal into a PRCS. Entry is considered to happen as soon as any part of the person s body breaks the plane of the entry portal. Entry Permit: The document developed and approved which describes entry conditions and grants access to the PRCS. See Appendix C2 for the Indiana University form. Entry Supervisor: The person responsible for determining if acceptable entry conditions exist at the PRCS, for overseeing entry operations, and terminating entry. Hazardous Atmosphere: An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue, injury or illness. Hazardous atmospheres include those with flammable components, airborne combustible dust, toxic or hazardous substances, and insufficient or excess oxygen levels. Hot Work Permit: Written authorization to perform operations such as welding, brazing, cutting, or burning capable of providing a source of ignition. Immediately Dangerous to Life or Health (IDLH): Any condition that poses an immediate or delayed threat to life or would cause irreversible health effects, or that would interfere with an individual s ability to escape unaided from a PRCS. 6
7 Inerting: The displacement of the atmosphere in a PRCS by a noncombustible gas (such as nitrogen). TE: This may produce an oxygen-deficient atmosphere. Non-Permit Confined Space: A confined space that does not contain or have the potential to contain any hazard capable of causing death or serious physical harm. Oxygen-deficient Atmosphere: An atmosphere containing less than 19.5 percent-by-volume oxygen. Oxygen-enriched Atmosphere: An atmosphere containing more than 23.5 percent-by-volume oxygen. Permit-Required Confined Space (PRCS): A confined space that has a potentially hazardous atmosphere, could engulf an entrant, has an internal configuration which could trap an entrant, or contains any other recognized safety or health hazard. Prohibited Conditions: Any condition in a PRCS that is not allowed by the permit during the period when entry is authorized. Rescue Service: Personnel designated to rescue employees from a PRCS. Retrieval System: Equipment used for non-entry rescue of persons from the PRCS. Testing: The process by which the hazards that may confront PRCS entrants are identified and evaluated. This includes specifying the tests to be performed in the PRCS. 7
8 APPENDIX B: SPECIFIC PROCESURES This section may be used for procedures specific to a given entry or a given site. 8
9 APPENDIX C: FORMS, LINKS TO FORMS (if applicable) Appendix C1: IOSHA s Decision Flow Chart for Confined Spaces: See following page 9
10 Does the workplace contain Confined Spaces as defined by (b)? Does the workplace contain Permit-required Confined Spaces as defined by (b)? Consult other applicable OSHA standards. STOP Inform employees as required by (c)(2). Will permit space be entered? Prevent employee entry as required by (c)(3). Do task from outside space. Will contractors enter? Task will be done by contractors' employees. Inform contractor as required by (c)(8)(i), (ii), and (iii). Contractor obtains information required by (c)(9)(i), (ii), and (iii) from host. Both contractors and host employees will enter the space? Will host employees enter to perform entry tasks? Coordinate entry ooperations as required by (c)(8)(iv) and (d)(11). Prevent unauthorized entry. Prevent unauthorized entry. STOP Does space have known or potential hazards? Can the hazards be eliminated? Not a permit-required confined space does not apply. Consult other OSHA standards. Employer may choose to reclassify space to non-permit required confined space using (c)(7). STOP* Can the space be maintained in a condition safe to enter by continuous forced air ventilation only? Space may be entered under (c)(5). STOP* Prepare for entry via permit procedures. Verify acceptible entry conditions (Test results recorded, space isolatedif needed, rescuers/means to summon available, entrants properly equipped, etc.) Permit not valid until conditions meet permit specifications. Permit issued by authorizing signature. Acceptable entry conditions maintained throughout entry. Entry tasks completed. Permit returned and cancelled. Emergency exits (prohibited conditoin). Entrants evacuated, entry aborts. (Call rescuers if needed). Permit is void. Reevaluate program to correct / prevent prohibited condition. Occurrence of emergency condition (usually) is proof of deficient program. No re-entry until until program (and permit) is amended. (May require new program). CONTINUE Audit permit program and permit based on evaluation of entry by entrants, attendants, testers and preparers, etc. 10
11 Appendix C2: Sample Permit Indiana University Office of Environmental, Health, and Safety Management Indiana University Permit-Required Confined Space Entry Permit A. Space Description 1. Type of confined space 2. ID # 3. Location 4. Entry Purpose 5. Hazard Identification 6. Start Date 7. Start Time a.m./p.m. 8. Scheduled Expiration a.m./p.m. B. Personnel The following person(s) trained in confined space procedures are assigned work in connection with a confined space entry, in accordance with this permit: 9. Entrants: Name (Printed) Name (Printed) 10. Attendants: Name (Printed) Name (Printed) C. Type of Entry 11. Permit-Required Confined Space (See Section G) 12. Alternate entry a. All employees trained b. Atmospheric hazard (identify) c. Atmospheric data available d. Ventilation and monitoring without entry e. Space atmosphere tested/no hazardous atmosphere f. Continuous ventilation during entry g. Continuous monitoring during entry 13. Reclassify space from Permit to Non-permit a. No atmospheric hazard present b. All other hazards eliminated before entry (list) Signature of Entry Supervisor 11
12 D. Safety Requirements 14. Area secured 15. Piping disconnected 16. Energy sources and mechanical hazards locked/tagged out 17. Cleaning (flushing/washing) done 18. Required purging or venting done 19. Sources of ignition controlled 20. Cutting, welding permit obtained 21. Use of hazardous or flammable materials approved 22. Other Yes No Date/Time Checked By E. Tests Test must be taken in the following order: Test to be Taken Limit Test Results Equip. Name 23. % of OXYGEN (O 2) % 24. % of LEL flammable concentrations <10% 25. CARBON MOXIDE (CO) <25 ppm 26. HYDROGEN SULFIDE (H 2S) <10 ppm 27. OTHER 28. TIME Serial No. Note: Continuous/periodic tests shall be established before starting job. Any questions pertaining to test requirements, contact your supervisor, safety officer, or IU Environmental Health & Safety. Note hazardous conditions under Section A, #5. F. Personal Protective and Safety Equipment 29. Retrieval line/hoist 30. Hard hat 31. Safety harness 32. Hearing protection 33. Eye/foot protection 34. Fire extinguisher 35. GFI in wet environment 36. Gas/oxygen/toxicity detector(s) 37. Ventilation equipment 38. Respirators (specify): 39. Protective clothing (specify): 40. Gloves (specify): 41. Communication equipment (specify): 42. Others (specify): Cal. Date Initials 12
13 G. Entry Procedures 43. Attendant understands duties 44. Entrant understands exit requirements 45. Attendant has communication to rescue personnel 46. Entrant has lifeline 47. Rescue plan is in place 48. Pre-Entry Briefing: I/We have reviewed this permit and are aware of the hazards and precautions necessary for performing the designated work in the confined space authorized by this permit: (Signed by all entrants & attendants) Name (Signature) Name (Signature) 49. Certification: I certify that all existing and potential hazards have been evaluated, necessary protective measures have been taken, and acceptable environmental conditions exist: Printed Name: Signed: Date: (Entry Supervisor) 50. Emergency Phone Numbers Other: Police Fire 51. Permit Cancelled/Closed at: on: by: (Entry Supervisor) Comments: 13
14 Appendix C3: Information Sent to Bloomington Fire Department for Use with Emergency Recovery Entry Site (Building or Street): Date: Location of Confined Space: Number: Time of Entry: am / pm TO: am / pm Type of ENTRY: Permit Space Non-Permit Space (circle one) Reason for Entry (Work to be performed): Number of persons performing entry: Contact Person (Entry Supervisor): Contact Phone Number: ( ) Hazards Present in Confined Space (CIRCLE ALL THAT APPLY) ELECTRICAL NATURAL GAS LP GAS WATER STEAM LINES SEWER RUBBLE / DEBRIS OTHER (EXPLAIN): All information must be filled out and form MUST be faxed to Bloomington Fire Department Fire Station Headquarters at # ENTRY shall be made until confirmation of notification has been made by calling the Battalion Chief on duty or Headquarters Captain at the following numbers: HEADQUARTERS: Ask for Battalion Chief or Headquarters Captain: (812) hrs BLOOMINGTON OFFICE: (812) if no answer at headquarters REGIONAL CAMPUSES: Insert your campus information 14
15 Appendix C4: Atmospheric Testing of Confined Spaces Atmospheric testing of confined spaces is required for two distinct purposes: C4.1 To evaluate the hazards of the permit space; and C4.2 To verify that acceptable entry conditions exist. All permit-required confined spaces must be tested before entry to ensure that the atmosphere meets all safety and health standards which are required for worker occupancy. Testing must be performed by authorized representatives of the Office of Environmental Health and Safety Management and/or qualified designees who have had adequate training and are assigned in writing to perform such duties. Confined spaces must be totally clear of any measurable contaminant and oxygen content must be between 19.5% and 23.5% prior to entry. Atmospheric testing must be conducted prior to and during initial venting or purging of the confined space. Prior to entry, an atmosphere which contains a measurable contaminant must: C4.3 Be ventilated with forced air (refer to Appendix C6) until the contaminant is completely purged; and C4.4 Have appropriate continuous ventilation and monitoring strategies put into place and documented on the entry permit. All air monitoring equipment shall be calibrated on a monthly basis and determined to be safe and ready to use by the responsible person or persons in the department where the equipment is kept and maintained. EHS personnel are available to provide assistance, as needed. Atmospheric testing shall be conducted in the following order: C4.5 Oxygen content C4.6 Combustible gasses C4.7 Toxic gases or vapors The atmosphere must be tested at the bottom, top, and middle of all confined spaces and continuously monitored while work is being conducted in the confined space. If the confined space is left for any reason, the atmosphere must be re-tested before anyone is allowed to reenter the space. Lockout/tagout procedures must be in effect as required prior to testing if practicable. The following list gives personal exposure limits for some of the most common hazards found in confined spaces: Oxygen deficiency oxygen level less than 19.5% per volume of air Oxygen enriched) - oxygen level above 23.5 % per volume of air Carbon monoxide - 35 parts per million (ppm), action level 17 ppm Hydrogen sulfide - 10 ppm 15
16 Appendix C5: PRCS Equipment List Indiana University Office of Environmental, Health, and Safety Management The following checklist may be used as a guide for pre-planning and pre-entry purposes. It is only a guide and may be added to and deleted from to meet operational requirements. Personal Protective Equipment Respiratory protection Hard hat Eye protection Hand protection Hearing protection Clothing, coveralls, boots, etc. Lockout/Tagout Equipment Locks, tags, etc. Blanking & blinding gear, etc. Notice to others who may be affected by a power outage, etc. Lighting Equipment Retrieval and Egress Equipment Safety harness Lifeline & mechanical retrieval system Ladder Emergency Equipment First aid kit Fire extinguisher Drinking water Portable Blower Ducting Ventilation Equipment Monitoring Equipment TMX 412 gas monitor Communications Equipment Radio, cell phone, etc. Emergency phone numbers Barricade Equipment Safety cones Barricades Signs 16
17 Appendix C6: Forced Air Ventilation Requirements To ventilate a confined space the following shall be done: An employee may not enter the space until the forced air ventilation has eliminated any hazardous atmosphere; The forced air shall be so directed as to ventilate the immediate areas where an employee is or will be present within the space and shall continue until all employees have left the space; and The air supply for the forced air ventilation shall be from a clean source and may not increase the hazards in the space. The atmosphere within the space shall be periodically tested as necessary to ensure that the continuous forced air ventilation is preventing the accumulation of a hazardous atmosphere. If a hazardous atmosphere is detected during entry the following shall be done: Each employee shall leave the space immediately; The space shall be evaluated to determine how the hazardous atmosphere developed; and Measures shall be implemented to protect employees from the hazardous atmosphere before any subsequent entry takes place. The authorized entry supervisor shall verify that the space is safe for entry and that the measures required in reclassification of permit to non-permit space have been taken. This is accomplished by a written certification containing the date, the location of the space, and the signature of the person providing the certification. The certification shall be made available to each employee entering the space. Appendix C7: Preparing to Enter a Permit-Required Confined Space Before each entry into a confined space the permit must be completed by the confined space entry supervisor or attendant. Authorized entrants or attendants must also conduct the following steps: C7.1 Fax completed form to the Bloomington Fire Department Fire Station Headquarters at (812) C7.2 Contact the Bloomington Battalion Chief on duty or Headquarters Captain at (812) Ask for Battalion Chief or Headquarters Captain 24 hours per day. If there is no answer, call the headquarters office at (812) or the Battalion Chief s cell phone at (812) Confirm that the confined space entry permit has been received. C7.3 Test the atmospheric conditions of the confined space to ensure that: Oxygen content is greater than 19.5% and less than 21.0%; Flammable gas is less than 10% of the lower explosive limit (LEL); and Toxic gas and vapors do not exceed the Permissible Exposure Limits (PEL). Entry conditions shall be continuously monitored in the areas where authorized entrants are working. 17
18 C7.4 Isolate all mechanical or electrical hazards in the space by following all lockout/tagout procedures. C7.5 Test or monitor the permit space as necessary to determine if acceptable entry conditions are being maintained during the course of entry operations. C7.6 Assist in identifying protective measures to take if any atmospheric or physical condition exists that makes the space unsafe for entry. C7.7 Obtain any equipment necessary to complete the job (See Appendix C5 for a suggested list of equipment that may be needed). If certain equipment is not available through your department, contact the Office of Environmental, Health, and Safety Management. C7.8 Ensure that each authorized entrant who enters a permit-required confined space wear a body harness and be connected to the tri-pod cable to facilitate non-entry rescue. If the tri-pod retrieval would increase the overall risk of entry or would not contribute to the rescue of the entrant other methods may be considered. C7.9 Obtain and complete a hot work permit. C7.10 Place any necessary signs or barriers around the space to prevent unauthorized entry and to control hazards created by opening up the space. C7.11 Ensure that qualified staff members have completed and signed the entry permit, reviewed it to make sure that all requirements are met, and that he/she understands the contents of the permit. C7.12 Brief all assigned workers on their roles, the work to be done, communication requirements, potential hazards and emergency procedures. This must be accomplished before anyone is allowed to enter the confined space. 18
19 APPENDIX D: ADDITIONAL REFERENCES AND RELATED PROGRAMS, (if applicable) 19
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