Confined Space

List Of Documents and Appendices:

I.  Purpose

To protect employees from the hazards of confined spaces at NCSU. To establish procedures for safe entry for NCSU employees and contractors.

2. Definitions:  See Appendix A for printable list.

3. Objective

To protect employees, contractors, students, and visitors from confined space hazards and to comply with OSHA standard 29CFR1910.146, “Permit Required Confined Spaces.”

Enclosed spaces, as defined under, 29CFR1910.269, “Electric Power Generation, Transmission, and Distribution,” and manholes, as defined under 29CFR1910.268, “Telecommunications,” are not addressed in this program.

4. Responsibilities – General

1. Supervisors
   1. Identifies areas that could be confined spaces reports them to University Occupational Safety. Assist with determination of hazards and confined space classification as either permit required or non-permit required. Request re-assessment of confined spaces when conditions change.
   2. Ensures relevant programs and procedures, including respiratory protection, fall protection, lockout/tagout, isolation, etc., are maintained and all affected personnel are properly trained and qualified according to program requirements.
   3. Ensures employees are properly trained on the confined space program according to their role as entrant, attendant, and/or entry supervisor. This includes training on air monitoring equipment, safety equipment, other equipment, tools, and procedures relevant to confined space operations.
   4. For each confined space entry, designates persons authorized to be entrant, attendant, and entry supervisor.
   5. Ensure employees who use equipment or tools during confined space operations are trained and qualified to use the tools or equipment,
   6. Ensure equipment used for confined space operations is properly maintained and appropriate equipment maintenance and calibration records are maintained.
   7. Review and approve Confined Space Entry Permits prior to entry, and sign entry permits on completion.
   8. Maintain entry permits for at least one year and evaluate entry permits annually. Ensure identified corrective actions are complete,

2. Environmental Health & Safety (EH&S)
   1. Maintain the University’s Confined Space Program, review it annually and document the review. Update the program as needed.
   2. Maintain an inventory of confined spaces as reported by supervisors. Evaluate and determine whether the spaces are normally permit or non-permit spaces.
   3. Ensure permit spaces are labeled or otherwise secured to prevent unauthorized entry.
   4. Assist supervisors and entry personnel in confined space hazard assessments, use of confined space entry procedures, including use of PPE.
   5. Assist supervisors with maintenance and calibration of air monitoring instruments.
3. University Project Managers
   1. Inform the contractor in writing that the workplace contains permit spaces. Project drawings, specifications, and bid documents must identify permit spaces including all access points.
   2. Notify the contractor in writing of the hazards that have been identified and/or the experience that the University has had with the space.
   3. Inform the contractor that all contractors and subcontractors are required to follow a PRCS Program that complies with OSHA regulations and NCSU entry requirements.
   4. Ensure the Contractor has affirmed compliance with PRCS requirements with all “yes” responses and signed the University’s “Contractor’s PRCS Affirmation” form, (Mandatory Appendix F). (This should be received during the bid process )
   5. Notify the contractor of any precautions or procedures that the University has in effect for employee protection in or near the space.
   6. Coordinate entry operations with the contractor when both University and contractor personnel will be working in or near permit spaces.
   7. Debrief the contractor at the conclusion of the entry operations regarding any hazards confronted or created in the space during entry.
   8. Report any confined spaces not on the list to NCSU Environmental Health & Safety

4. Employees
   1. Successfully complete the required training.
   2. Respect and do not alter barriers, lockouts/tagouts, or other confined space equipment.
   3. Do not distract the Attendant when not involved in the entry.
   4. Do not enter a permit space unless an entry permit has been completed and attendant is on duty.

5. Responsibilities of Entry Personnel

Personnel involved in a permit space entry must be trained in the duties of their role(s) and authorized to do them. Every permit entry must have a person assigned by the supervisor for:

1. Entry Supervisor – person who verifies proper hazard evaluation, whether appropriate tools and equipment is on hand, that the rescue plan is completed and is generally responsible for the safe conduct of the permit space entry.
2. Entrant – person who enters the space.
3. Attendant – person who monitors entrants, protects the entry area, and summons help, e.: activates the rescue plan, and attempts non-entry rescue if needed.

For entries conducted under Alternate Procedures, see Section 3 under “Permit Space Entry,” there is no requirement for an attendant, however:

1. Non-entry retrieval must always be used where possible; therefore, an attendant may be required for non-entry retrieval.
2. All entries without an attendant must have a minimum of two entrants who will monitor each other. Entrants are required to stay in close visual contact.

An entrant can also serve the role of entry supervisor. An attendant can only be an attendant. Individuals can hand off roles to other individuals as long as there is always an entrant, entry supervisor, and a separate person serving as attendant.

Specific roles and responsibilities are described in the respective appendices:

• Entry supervisors: Mandatory Appendix B.
• Entrants: Mandatory Appendix C.
• Attendants: Mandatory Appendix D.

 6. Program Planning

1. Identification of Confined Spaces:
   1. Each supervisor shall perform a workplace risk assessment to identify confined spaces in their work areas.
   2. The supervisor shall provide a list of confined space locations to EH&S.
2. Confined Space Hazard Assessment:
   1. Environmental Health & Safety and the supervisor shall assess the hazards and the potential for hazards to develop in and around the confined spaces.
   2. The hazard assessment shall be documented using (Mandatory Appendix E.)
   3. Supervisors are responsible for maintaining the permit space hazard assessment documentation for spaces under their control and for requesting a new assessment if conditions change.
   4. The assessment shall identify all energy sources, moving equipment, and pipe inlets which must be controlled before entering the space.
   5. The assessment shall identify atmospheric and physical hazards:
      Atmospheric Hazards:
      asphyxiating,
      flammable,
      toxic, irritant, corrosive, etc.
      Physical Hazards:
      1. moving parts or machinery,
      2. engulfment by liquid or finely divided particles,
      3. slips, trips, or falls,
      4. electrocution or shock,
      5. noise (may limit entry time),
      6. radiation,
      7. thermal (hot or cold burns),
      8. heat stress or cold stress (may require work/rest cycles),
      9. hazardous materials,
      10. any other serious hazard,
      11. internal configuration that could trap or asphyxiate an entrant by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross section,
      12. configuration that could create an impediment to self-rescue.

3. Confined Spaces that normally or potentially have any recognized hazard shall be considered Permit Required Confined Spaces (PRCS) (Permit Spaces) and shall be labeled. Access by unauthorized persons shall be prohibited. Entries into permit spaces shall be done under this program.
4. Enclosed spaces:
   1.  This program does not apply to entries into enclosed spaces, except.
   2. Enclosed spaces that include manholes, vaults, tunnels, or shafts containing electric   power generation, control, transformation, transmission, and distribution lines or equipment; and are not designed for employee entry under normal operating conditions are considered confined spaces. Entries into such spaces shall be done under this program.
   3. Similarly, such enclosed spaces that are expected to contain a hazardous atmosphere are considered permit required confined spaces. Entries into such spaces shall be done under this program.
5. Facilitating Contractor Entries:
   1. Contractors shall follow OSHA and NCSU policies and requirements.
   2. Contractors are responsible for having their own PRCS program for their employees and shall be informed of any University specific safety information, such as how to contact NCSU Campus Emergency Services.
   3. Contractors shall use their own entry permit and PRCS program and to have their own rescue plan. Contractors shall affirm their entry program complies with OSHA and NCSU requirements using (Mandatory Appendix F.)
   4. All contractors shall be informed of any known hazards and/or past experiences that University employees may have had with the PRCS to be entered. At the conclusion of a contractor’s entry operations, the University’s Project Manager shall debrief the contractor regarding the entry procedures used and whether the contractor encountered any hazards that were not known or if any hazards were created during entry.
6. Coordinating entries with more than one employer:
   1. When employees of more than one employer are working in or near the same permit space, each employer shall coordinate entry operations through the University’s Project Manager, so employees of one employer do not endanger others.
   2. Entrance to the permit space shall be maintained free of hazards and
   3. Each employer shall have their own permit system.
   4. Only an NCSU employee may be attendant for NCSU employees entering a permit space.
7.  Entry Into non-permit spaces:
   1. Before entry into non-permit confined spaces, the supervisor shall determine whether conditions have changed that might make the space a permit space. Examples include introduction or intrusion of hazardous substance, including flooding, or hazardous atmosphere, active steam release, or known or assumed structural failure. If such conditions develop, the supervisor shall contact EHS to assist with the hazard assessment and conduct a permit entry.
   2. If non-permit confined spaces have no hazards, entry can be made without using the permit system.

 

7.   Permit Space Entry – Working In Permit Required Confined Spaces

1. The entry permit – (Mandatory Appendix G.)
   1. An entry permit is required for every entry into a permit required confined space,
   2. Detailed guidance for using the NSCU Confined Space Entry Permit are found in Appendix G.1.
2. Full Permit Entry,
   1. A full permit entry is required for entry into permit spaces where:
      1. All physical hazards cannot be eliminated, or,
      2. Any actual or potential atmospheric hazards cannot be eliminated or
      3. Examples of this include working in inert atmospheres, working in permit spaces where hazards cannot be isolated outside the space, where introducing hazards that cannot be eliminated, or for atmospheric hazards, cannot be eliminated or controlled by forced air ventilation.
   2. Purging and cleaning:
      1. Permit spaces that contain hazardous materials or atmospheres may need to be purged and cleaned prior to entry
      2. Special precautions are required for spaces that have contained flammable or combustible materials or that may generate hazardous atmospheres.
      3. Contact Environmental Health & Safety, env-health-occ-safety@ncsu.edu, or 919-515-7915, if purging or cleaning a permit space is required.

2. 1. A rescue plan is required for full permit entry:
      1. Pre-planning and coordination with responders is required for a timely response. In most cases where a timely response is required, the response team will need to be on-site and ready for a rescue entry. Do not expect a timely response simply by calling 911,
      2. If respiratory protection is required, entrants must be approved and trained to wear the designated respirator according to the NCSU respiratory protection program.
      3. A comprehensive safety evaluation of the anticipated hazards, and proposed work in the permit space must be done.
      4. EHS must be included on the evaluation team. Contact env-health-occ-safety@ncsu.edu, 919-515-7915.

4. Declassifying a permit to a non-permit space:

If all physical and atmospheric hazards in a permit space can be eliminated, the space may be declassified to a non-permit space.

1. ALL hazards must be eliminated, not just controlled.
   1. Electrical hazards have been eliminated by Lockout/
   2. All other physical hazards have been eliminated by Isolation:
      • Blanking and blinding, or
      • Double block and bleed, or
      • Misalignment of pipes, or
      • Physical immobilization of movable parts.
   3. There is no evidence of a physical hazard present in the space.
   4. There is no atmospheric hazard.
   5. There is no potential atmospheric hazard.
2. A confined space permit is not required.
3. Use of Alternate Procedures:
   1. The majority of permit space entries at NCSU occur using Alternate Procedures, as defined in 29CRF1910.146(c)(5). For entries using Alternate Procedures:
      1. There are no physical hazards.
      2. Atmospheric hazards and potential atmospheric hazards can be controlled using forced air ventilation.
      3. An entry permit must be completed.
      4. No rescue plan is required, but Section 12a of the entry permit must be completed listing the supervisor’s contact info and other details. The entry team should plan what to do in an emergency
      5. An attendant is not required EXCEPT where non-entry retrieval is possible. In which case, the attendant must perform all relevant attendant responsibilities.
      6. Entrants where no attendant is required shall not work alone.
      7. Continuous air monitoring is required and must be documented at approximately 60 minute intervals. This can be done by the attendant; or if there is no attendant, by one of the entrants.
   2. Work tasks where Alternate Procedures may be used include:
      1. Walkthrough inspections or other tasks that do not include manipulating valves fittings, or other equipment; where the physical hazards are contained in enclosed piping, tanks, and system components; and atmospheric hazards are controlled using forced air ventilation.
      2. Work done in permit spaces where physical hazards have been eliminated by isolation (see below) and atmospheric hazards are controlled using forced air ventilation.
      3. Alternate Procedures, Section 11 on the Confined Space Entry Permit (Appendix G) can only be used when there are no physical hazards and all actual and potential atmospheric hazards can be controlled by forced air ventilation.
         1. There are no exposed physical hazards
         2. Electrical hazards have been eliminated by Lockout Tagout.
         3. All other physical hazards have been eliminated by Isolation, see below:
            1. Blanking and blinding, or
            2. Double block and bleed, or
            3. Misalignment of pipes, or
            4. Physical immobilization of movable parts.
      4. There is no evidence of a physical hazard present in the space.

2. Atmospheric Hazards have been controlled by forced air ventilation.
   1. Ventilation:
      1. Select a fan with enough capacity to quickly replace the volume of air in the space.
      2. Use only fans in good working order.
      3. Observe safety and warning labels on the fan.
      4. Position the fan where it will take in clean, fresh air. Be careful about automobile and generator exhaust fumes.
      5. Use a flexible duct to deliver air into all areas of the space. (Generally, the duct must be at least 3 feet into the space.)
      6. Ventilate for a minimum of 5 minutes before verifying acceptable entry conditions are present and entering.
      7. Continue to ventilate throughout the entry operation.
   2. When forced air ventilation is used, acceptable entry conditions are Limit monitors on instrumentation must be adjusted accordingly:
      1. Lower flammable limit is 5% instead of 10%.
      2. Hydrogen sulfide limit is 5 PPM instead of 10 PPM.
      3. Carbon monoxide limit is 25 PPM instead of 50 PPM.
      4. All other occupational exposure limits are reduced by 50%.
   3. Continuous atmospheric monitoring is required for all Measurements must be recorded at approximately 60 minute intervals.
   4. Immediately evacuate the permit space for any atmospheric monitor reading not within defined acceptable entry conditions.
   5. Routine entries, not requiring isolation, can often be done using a permit template, pre-filled with some information.

1. Only the following entry permit sections (Appendix G), indicated by this symbol “►,” may be pre-filled:
   1. Parts of Section 1 Space identifier.
   2. Section 2 Identification of Potential Hazards.
   3. Section 3 Required Work Procedures/Controls.
   4. Parts of Section 7 Ventilation.
   5. May pre-fill type of ventilation.
   6. Flow rate must be verified for each entry.
   7. Sections 13a & 13b Equipment.
2. For every permit, the Entry Supervisor is required to review the pre-filled sections of the permit and verify that all routine conditions are applicable. If conditions have changed, a new permit must be completed.
3. Signatures are required for every entry as follows:
   1. Section 11b Alternate Procedures Approvals – entrant and entry supervisor.
   2. Section 16 Versifications.
      1. Person completing the pre-job worksheet (e.g.: work order), usually the line supervisor. Person completing the permit, usually the entry supervisor.
      2. Reviewed and approved by the entry supervisor.
      3. Verification by the entrant
   3. Section 17 Post Entry, “Confined space secured by:” Usually signed the entry supervisor.
   4. The line supervisor shall review the entry permit and verify the permit was completed thoroughly and accurately. The supervisor shall initiate corrective action for any discrepancies, deficiencies, or irregularities.

Note: The Entry Supervisor’s signature indicates approval of all information including pre-filled information.

3. Acceptable Entry Conditions – (Mandatory Appendix H)
   1. By definition, a permit required confined space is a space with limited means of entry and egress and has physical hazards, atmospheric hazards or both. In order to ensure the space is safe for entry, the listed conditions must be met prior to entry.
   2. During the entry should entry personnel determine or receive any indication that ALL acceptable entry conditions are no longer present the space shall be immediately evacuated and a hazard assessment conducted before another entry is started.
4. Signs and symptoms of exposure to common atmospheric hazards – (Appendix I)
5. Equipment required for permit and non-permit space entry – (Appendix J)
   1. Air monitoring equipment.
   2. Personal Protective Equipment.
   3. Tools: hand, electrical power, pneumatic, welding.
   4. Retrieval and Rescue equipment.

9. Isolation:
   1. Isolation is a process for eliminating hazards:
      1. All entrants are required to apply their own locks to all applicable isolation devices.
      2. Electrical hazards can be isolated using Lockout/Tagout controls or by disconnecting conductors. Stored electrical energy can be isolated by disconnecting or grounding.
      3. Electrically or pneumatically controlled solenoid valves can be isolated by deenergizing and locking out the control energy. The lockout procedure shall define whether the valve should fail open or closed.
      4. Flowable physical hazards, such as steam, water, or liquids contained in tanks, or enclosed in sealed piping and piping components such as valves and traps must be isolated outside the permit space and can only be isolated by one of the following:
         1. Blanking and blinding,
         2. Double block and bleed,
         3. Misalignment of pipes.
      5. Physical hazards from moving or movable parts or from falling parts or equipment can be isolated by immobilizing, blocking, chocking, or restraining movable parts, and by blocking and supporting parts that can fall.
      6. Atmospheric hazards contained in piping, such as nitrogen, natural gas, or other hazardous gases can be isolated, outside the space, using:
         1. Blanking and blinding,
         2. Double block and bleed,
         3. Misalignment of pipes.
      7. Physical hazards contained by bursting discs, frangible, discs, pressure relief, or other emergency release valves or components (automatic or manual) must be isolated. Atmospheric hazards must be isolated or forced air ventilation must be adequately sized to control the hazard.
      8. Forced air ventilation is not isolation or elimination of atmospheric hazards. Forced air ventilation can only be used to control atmospheric hazards.
   2. Isolation Required:
      1. Examples of work requiring isolation of steam, water, or other flowable hazard include:
         1. Line breaking.
         2. Installation, repair, or demolition of system components.
         3. Adjusting or tightening compression seals such as flanges.
         4. Draining or releasing hot water from steam traps or condensate lines.
         5. Any work in normally flooded spaces such as boilers and water tanks.
      2. Isolation is required to declassify a permit space to a non-permit space.
      3. Isolation may or may not be required for entry using alternate procedures.
         1. Isolation is NOT Required in permit spaces where there is no expected exposure to physical hazards for the following tasks:
            1. Walkthrough inspections of tank dikes, steam tunnels and vaults.
            2. Minor manipulation of valve handles to adjust
            3. Adjusting or tightening a packing gland.
            4. When physical hazards are contained or enclosed.
               1. Electrical hazards are enclosed in conduit or enclosures.
               2. Flowable physical hazards, such as steam, water, or liquids are contained in tanks, enclosed in sealed piping and piping components such as valves and traps and where there is no eminent risk of direct exposure to the contained hazard.

10. Maintaining Safe Entry Conditions. See (Mandatory Appendix H): Acceptable Entry Conditions.

1. General
   1. Continuous atmospheric monitoring must be maintained for all entrants.
   2. Where heat stress is an identified hazard, periodic wet bulb globe temperature monitoring may be required for entries.
   3. Use forced air ventilation to control atmospheric hazards.
2. Hazards brought into the space.
   1. Air powered tools may introduce contaminated air that does not meet breathing air quality specifications. Be aware of the potential for carbon monoxide buildup.
   2. Welding or hot work can introduce physical and atmospheric hazards, including:
      1. Sparks and ignition sources,
      2. Toxic welding gases.
      3. Combustion gases and particles from welding.
   3. Electrical equipment brought into a permit space must be suitable for the space conditions. Consider using GFCI protection, explosion proof, or intrinsically safe equipment, if necessary.

11. Communications

1. Entrants and attendants shall communicate with each other, and the attendant shall document it, at approximately 60 minute intervals. Routine communication is sufficient to meet this requirement.
2. For entries with no attendant, such as when doing a walk-through inspection, one of the entrants shall document the communications checks.
3. Methods of communication may be by talking, shouting or two-way radio. Avoid using visual hand signals.
4. The method of communication shall be effective under all anticipated conditions of entry
5. If, at any time, the attendant cannot contact an entrant, the attendant must initiate an emergency rescue.
6. If the communication fails, e.: either the attendant cannot contact an entrant or an entrant cannot contact the attendant or another entrant, all entrants must immediately leave the permit space.
7. The attendant shall have a means available to initiate an emergency response.

12. Post-Entry

1. The attendant and entry supervisor will ensure that all entrants have left the space.
2. The attendant and entry supervisor shall ensure that all tools and equipment have been removed from the space. No compressed gas bottles may remain in any permit space after the entry is complete.
3. The attendant or entry supervisor shall secure the space from unauthorized entry and document these steps by signature in Section 17 of the entry permit.
4. Return the entry permit to the supervisor.
   1. The line supervisor will review the entry permit and affirm that it was properly completed and all appropriate signatures are included.
   2. The supervisor will initiate appropriate corrective action for deficiencies noted during the entry or based on the entry permit.
   3. The supervisor will sign and date the bottom of the entry permit to affirm appropriate completion or the permit and, if needed, corrective actions.

13. Training

1. All personnel involved in the entry will be properly trained on the appropriate responsibilities of their role. This includes:
   1. The line supervisor who assigns personnel to their entry roles.
   2. The entry supervisor who is responsible for the safe conduct of the entry.
   3. The attendant who is responsible for the safety of entrants and for maintaining a safe point of entry and egress.
   4. The entrant who is responsible for working safely in a confined space.
2. Person(s) who are required to wear respiratory protection shall be trained according to NCSU’s respiratory protection program.
3. Training is also required for:
   1. Personal Protective Equipment.
   2. Ladders
   3. Use of retrieval equipment.
   4. Use of a personal fall arrest system for retrieval.
   5. Use of atmospheric monitoring equipment.
   6. Use of tools and equipment needed to complete the work in the permit space.