CONFINED SPACE PROGRAM
MurrayStateUniversity
Department of Facilities Management
Environmental Safety & Health
2012
1 Introduction
The Murray State University (MSU) Confined Space Program (CSP) designates practices for the safe entry, exit, and work in all confined spaces. The program also ensures that MSU is in compliance with the applicable standards for identifying and entering all permit-required confined spaces, as described below.
Confined space, as defined by the Occupational Safety and Health Administration (OSHA), means a space that:
• Is large enough and so configured that an employee can bodily enter and perform assigned work; and
• Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits); and
• Is not designed for continuous employee occupancy.
Depending on the hazards that may be associated with a confined space, it is classified either as 1) a permit-required confined space, also called a permit space; or 2) a non-permit-required confined space, also called a non-permit space. Permit spaces are so called because they contain additional hazards, and permits must be developed for the safe entry, exit and work in these spaces. Non-permit spaces warrant special consideration, but do not require permits unless the work done in the space creates a hazard. These classifications are defined more fully below:
Permit space means an area that meets the definition of a confined space and that has one or more of the following characteristics:
• Contains or has the potential to contain a hazardous atmosphere; or
• Contains a material that has the potential for engulfing an entrant; or
• Has an internal configuration so that an entrant could be trapped or asphyxiated by means of inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section; or
• Contains any otherrecognized serious safety or health hazard.
Examples of permit spaces at MSU include:
• Sump pits greater than 4 feet deep (due to potential atmospheric hazards, and also engulfment, mechanical or electrical hazards).
• Fuel tanks (due to atmospheric hazards).
• Boilers (due to atmospheric, electrical, and mechanical hazards).
• Irrigation system manhole pits (due to potential atmospheric hazards).
• Miscellaneous tanks (due to potential atmospheric hazards).
• Grain bins (due to engulfment hazards).
Non-permit space means an area that meets the definition of a confined space but that does not have any of the additional characteristics associated with a permit space.
Examples of non-permit spaces at MSU include:
• Crawl spaces above the ceiling and under the floor
• Pipe chases
• Pits less than four feet deep
• Mechanical rooms with restricted access
• Supply side of air handling systems with no mechanical hazards (i.e., close proximity to rotating fan blades)
A space that is normally classified as a non-permit space can become a permit space if the attributes of the space change; or, if the work to be done in the space creates one of the hazards that are characteristic of a permit space. For example, work with a flammable or toxic chemical in a space that is normally a non-permit space can make that space a permit space for the duration of the project.
The MSU Confined Space Program establishes procedures and provides tools for employees to evaluate confined spaces and the work to be conducted within the space to determine if a permit is required. This program establishes procedures for issuing permits and providing training to employees so they can recognize both non-permit and permit spaces. It also provides mechanisms for reclassifying permit spaces to non-permit spaces so that a permit is not necessary for entry. The steps required to conduct a safe entry increase with the greater complexity or hazards in a given space.
To help those departments affected by the Confined Space Program, many tools and pre-written entry procedures have been included in the MSU Confined Space Program. For example, procedures for work in steam tunnels are included in this program, as are boiler entry procedures. There are also Alternate Entry Procedures in Appendix G, for generic entries into permit spaces where the only hazard posed, atmospheric hazard, can be eliminated through continuous ventilation of the space. Other important procedures to be aware of include the Atmospheric Testing Procedures in Appendix E and the Permit Space Entry Procedures in Appendix F.
The Atmosphere Testing Procedures are designed to detect potentially hazardous atmospheres in permit spaces and non-permit spaces where it is suspected that conditions may have changed. These procedures are also used to verify that engineering controls in permit spaces have been effective in controlling the hazard. The Permit Space Entry Procedures describe the steps that must be taken to conduct a safe and lawful entry into areas designated as permit spaces.
There are many other tools provided in the appendices to the MSU Confined Space Program. These tools are intended to guide users in properly assessing, testing, and entering confined spaces. As an example, the preliminary hazard assessment form guides users in identifying hazards associated with a particular space. The remainder of this written program more fully describes the operation of the MSU Confined Space Program.
1.1 Policy
All persons involved with the confined space entry program at MSU must have appropriate training and follow the procedures outlined in this document for safe entry and work in confined spaces.
1.2 Application
This program applies to all campus facilities where there is a need to perform any activity in a confined space. More specifically, this program applies to all departments that have jurisdiction over employees or contract employees who enter confined spaces. Contractors operating on MSU property are required to comply with all applicable provisions of OSHA's Confined Space regulations. Contractors must comply with the provisions of MSU’s program only when making joint entries with MSU staff.
1.3 Regulatory Authority
The development and implementation of the MSU Confined Space Program is in accordance with the regulations of the OSHA Confined Space Standard, 29 CFR 1910.146. All state and federal regulations relating to procedures in this document are on file in the MSU Environmental Safety and Health (ESH) office and are available for review.
1.4 Glossary
Terms used in this document can be found in Appendix A.
2Program Elements
This program is designed to ensure safe entry and work in permit and non-permit spaces at MSU through:
• Identification and classification of confined spaces (Section 2.1).
• Posting of spaces (Section 2.2). Identified permit spaces may or may not be posted, depending on the likelihood of the space being entered. Posted spaces have caution signs with a space identification number and a telephone number to call prior to entry.
• Designation of Confined Space Entry Supervisors (CSESs), Authorized Entrants, and Authorized Attendants (Section 2.3).
• Training of MSU employees who may encounter and/or enter confined spaces (Section 2.4).
• Conducting pre-entry assessments of confined spaces to determine current conditions and proper classification of the space based on work to be conducted (Section 2.5).
• Determination of appropriate entry procedures applicable if the space is a permit space, as determined from the pre-entry assessment (Section 2.6).
• General controls for safe entry of both non-permit and permit spaces (Section 2.7).
• Coordination with contractors who may enter confined spaces (Section 2.8).
• Emergency rescue contingency plans (Section 2.9).
• Periodic review and revision of the MSU Confined Space Program (Section 2.10).
2.1Identification And Classification Of Confined Spaces
An initial inventory of Confined Spaces located on MurrayStateUniversity properties has been prepared by ESH with the cooperation of individual departments. This inventory identifies spaces that meet the definition of a confined space and further classifies these spaces as permit spaces or non-permit spaces.
For each type of space evaluated (e.g., pipe chases, pits, etc.), a Space Assessment Profile (SAP) has been prepared that provides additional information about common attributes or hazards associated with that type of space. Each type of space has an assigned SAP code, a list of which is provided in Appendix B. The SAP details the decision logic used to classify types of spaces as a permit or non-permit spaces. The SAP describes potential hazards associated with a type of space, appropriate personal protective equipment, whether the spaces have been posted, and data from previous atmospheric hazards testing.
SAP information can help Confined Space Entry Supervisors assess spaces and determine appropriate entry procedures. The SAP information is available from ESH.
It is the responsibility of departments to provide information to ESH if the use, configuration, or condition of a space their employees enter has changed, or if new confined spaces or potential confined spaces are identified or added. ESH will use this information to update the Confined Space Inventory.
2.2Posting Requirements And Signage
Permit spaces are listed on the MSU Confined Space Inventory. Many permit spaces are labeled, but some are not. Spaces that can be readily entered are required to have caution signs. These labeled, permit spaces have a yellow and black caution sign that states:
CAUTION
CONFINED SPACE NO.______
ENTRY PERMIT-REQUIRED. CALL______
The unique space I.D. number (no.) on the sign references the information regarding that space in the Confined Space Inventory. The telephone number on the sign is to a central location that must be called to initiate the process of safe entry into the confined space. Missing or damaged signs should be reported promptly to ESH.
Not all permit spaces are posted. Permit spaces are not posted where it is not practical to post signs at the entrance and the space is secured from unauthorized entry. Examples of such spaces include electrical vaults and manholes. Permit spaces are also not posted where the space is easily identified and unlikely to be entered because of difficult entry (e.g., a water tank). MSU employees will be trained to identify these spaces and not to enter them unless authorized and properly trained on entry procedures.
2.3Designation of Entrants, Attendants and Entry Supervisors
When it is necessary to enter a permit space, several individuals will be involved: confined space entry supervisors, authorized entrants, and authorized attendants. The confined space entry supervisor (CSES) conducts most of the up-front work in preparation for entry into a confined space. This person is responsible to ensure that the space is evaluated and appropriate entry procedures are selected prior to entry. ESH will, upon request, function as the CSES for those departments that enter confined spaces infrequently. Departments that enter confined spaces on a routine and frequent basis will need to designate one or more individuals from their department to serve as CSESs. Responsibilities of the CSES are more fully described in Section 3.3.
Authorized employees who actually bodily enter confined spaces are called entrants. To ensure the safety of the authorized entrants, attendants are stationed at the entrance to a confined space. The roles of attendants and entrants are fully described in Sections 3.4, and 3.5, respectively. Departments must determine which employees will serve as authorized entrants and attendants and must ensure that these employees are trained in accordance with Section 2.4.
2.4Training
There are three sections of the Confined Space Training program: Awareness Training; Permit Space Entry Training; and Permit Space Specific Training. A list of training topics for each section of training is provided in Appendix C.
Awareness training is provided to all individuals who may encounter or enter non-permit or permit spaces as part of their assigned duties, and their supervisors. This training is designed to provide participants with an overview of confined space issues. All maintenance workers at MSU and any additional staff identified by ESH who may encounter confined spaces as a routine part of their work, regardless of whether they enter such spaces, must receive confined space awareness training.
Permit space entry training is designed for those individuals who may be required to participate in the entry of a permit space, including CSESs, entrants, and attendants. Designated employees must participate in this training session, which includes coverage of the provisions of the OSHA Confined Space Standard and the MSU Confined Space Program. This training is provided or arranged for through ESH. ESH maintains associated training records and provides copies to participants and their respective departments.
Permit space specific training is to be provided to authorized entrants and attendants by the CSES at the following frequency:
• Prior to the first entry to a specific permit space; and
• When personnel are assigned a new task or duty in or associated with a space for which they have not been trained; and
• When a new hazard is introduced or recognized in a given permit space.
Permit space specific training must include the specific operations, safety equipment, monitoring equipment, emergency procedures, and other precautions for entry into the space. The CSES is required to generate, collect, and maintain records of space specific training. ESH will maintain such records only when acting in the capacity of the CSES on behalf of the department. The permit space specific training section of Appendix C is a tool that can be used by CSESs to ensure that the training they provide is adequate.
All training records shall include the trained employee's name, trainer's signature or initials and the date(s) and content of training. For space-specific training, the entry permit can be used to document training.
2.5Confined Space Pre-Entry Assessment
Because conditions associated with confined spaces can change over time, precautions should be taken prior to entering all confined spaces, including non-permit spaces. The pre-entry assessment is the tool that is used to detect changed conditions and to ensure safe entry into non-permit and permit spaces.
Appendix D includes a flow chart that illustrates the pre-entry assessment procedures described in this section. Form ESH-CSP-01, Pre-Entry Hazard Assessment, provides a format for conducting a pre-entry hazard assessment.
The pre-entry assessment is basically a thought and information-gathering process used to determine the status of the space prior to entry within the context of the work to be performed in the space. The employee that plans to enter and work in the confined space makes the initial pre-entry assessment by first determining whether the required task(s) can be accomplished from outside of the space using alternate technology or locations for work on a system. If the work can be conducted without entering the space, it should be accomplished as such and the provisions of the Confined Space Program are not initiated at all.
If the space must be entered, the next step for the employee is to determine if the space has been designated as a permit space. There are two easy ways to determine if a space has been designated as a permit space. The first is by looking for a sign. If thespace has been posted with a caution sign, it is a permit space, and the employee must call the telephone number on the sign to initiate the entry process.
Since some permit spaces are not labeled, looking for a sign cannot be the only method used. If the space does not have a sign, and the employee does not know the status of a given space through previous training, they must contact their supervisor or ESH to obtain the space status (non-permit or permit). The pre-entry assessment for all permit spaces is to be conducted by the CSES using procedures in Section 2.6, and the employee may not enter the space until the assessment is completed.
If the space has been designated as a non-permit space, the employee must be aware that the space could become a permit space if the work that they will be doing within the space introduces a new hazard; or if space conditions have changed substantially since the initial space assessment. The employee must contact their supervisor to arrange for a full pre-entry space assessment by a CSES if:
• There is evidence the configuration of the space has changed.
• There is evidence a new hazard may be present (e.g. an unusual odor in the space or uninsulated electrical wiring).
• The work the employee must do in the space will introduce a serious safety or health hazard.
• The employee has any concerns about the entry.
If none of these conditions apply, a full pre-entry assessment is not required, and the employee may proceed to do work in the non-permit space, taking appropriate general safety precautions.
If, however, one of these conditions exists, the employee must contact their supervisor because a full pre-entry assessment must be done by a CSES prior to entry. When a full pre-entry assessment is used by the CSES to establish appropriate entry procedures for a non-permit space, the complexity of the entry procedures will depend on the hazards identified through the pre-entry assessment process and the final classification of the space.