S06 - 585-19-118 - Att - Confined Space Entry FINAL JAN 2019.pdf

SOP 138-12-11 Attachment 1

OSCAR G. JOHNSON Engineering Service VA MEDICAL CENTER Standard Operating Procedure IRON MOUNTAIN, MI 49801 Policy 138-12-11 January 2, 2019

CONFINED SPACE ENTRY

1. Purpose: To establish a medical center policy governing the health and safety of personnel who enter a confined space.

2. Definition: Confined Space is defined as 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 (for example, tanks, vessels, silos, storage bins, hoppers, drums, and pits), and is not designed for continuous employee occupancy.

3. Policy: It is the policy Engineering Service to make confined spaces safe for employees by establishing safe working practices, monitoring confined space environments, and training employees to minimize the hazards associated with confined spaces.

4. Responsibility:

a. Medical Center Director has the ultimate responsibility for the occupational health and safety of all medical center employees.

b. Chief, Engineering Service, is responsible for:

(1) Controlling access to confined spaces for both “permit” and “non-permit” required air monitoring situation [29CFR1910.146 (c) (3)]. See Attachment 1, Confined Space Entry Form.

(2) Ensuring personnel are properly trained and training is documented [29CFR1910.146 (j) (4)].

(3) Providing equipment necessary for confined space entry and rescue [29CFR1910.146 (j) (2)].

(4) Shall ensure that the contractors are informed on the hazards, precautions, and procedures involved with working in identified confined spaces [29CFR1910.146 (c) (8)].

(5) Label confined spaces per OSHA requirements [29CFR1910.146(c) (2)].

c. Industrial Hygienist is responsible for:

(1) Monitoring the confined space for oxygen deficiency, toxic materials, and explosive vapors prior to and/or during work operations for permit required confined space entry.

(2) Coordinating medical surveillance of any employees who may have been exposed to a health hazard.

(3) Identifying and maintaining permit and non-permit confined space inventories [29CFR1910.146 (c) (1)].

(4) Determining what precautions are required.

(5) Review of confined space entry permits [29CFR1910.146 (j) (2)] [29CFR1910.146 (d) (14)] [29CFR1910.146 (e) (6)].

(6) Maintenance of copies of cancelled entry permits for at least one year and review the permits to identify any changes to the permit system as needed [29CFR1910.146 (d) (14)] [29CFR1910.146 (e) (6)].

d. Engineering Maintenance & Repair Supervisor is responsible:

(1) To ensure that all safety precautions and training are taken prior to entry and to brief entrants and attendants on the hazards of the confined space prior to entry [29CFR 1910.146(j)(2)]. [29CFR 1910.146(g)(4)] [29CFR 1910.146(e)(2)].

(2) To ensure attendant has a communication device and understands how to summon rescue services and other emergency response personnel [29CFR 1910.146(j)(4)].

(3) To post the entry permit at the entry point of the confined space [29CFR

1910.146(e)(3)].

(4) To terminate entry and cancel the entry permit when operations covered by the permit have been completed or a condition that is not allowed under the entry permit arises in or near the permit space [29CFR 1910.146(e)(5)] and to forward cancelled entry permit, or copy, to the Safety Officer.

(5) To conduct review after cancellation of entry permit with authorized entrants for any problems encountered during the confined space work.

e. Contractors are responsible for following the requirements of their company policies and this facility’s confined space policy. Contractor personnel who perform activities in permit-required confined spaces shall be trained according to 29CFR 1910.146, Permit-Required Confined Spaces, and have proof of training.

f. Entry Supervisor:

(1) Ensures that the confined space checklist/permit is properly completed and signs the checklist/permit form to authorize work.

(2) Signs the checklist/permit after the work is complete and the area is safe.

g. Authorized Entrant(s):

(1) To be trained and to understand the hazards that may be present during entry. Reads and signs the permit before entry [29CFR 1910.146(h)(1)].

(2) To properly use equipment specified as required by the confined space permit [29CFR 1910.146(h)(2)].

(3) To stay in constant communication with the attendant [29CFR

1910.146(h)(1)].

(4) To alert the attendant whenever conditions change within the confined space that may adversely affect the entrant, and immediately exits the confined space if continuous entry becomes hazardous [29CFR 1910.146(h)(4)] [29CFR 1910.146(h)(5)].

(5) Each authorized entrant shall use a chest or full body harness, with a retrieval line attached at the center of the entrant's back near shoulder level, above the entrant's head, or at another point which the employer can establish presents a profile small enough for the successful removal of the entrant. Wristlets may be used in lieu of the chest or full body harness if the employer can demonstrate that the use of a chest or full body harness is infeasible or creates a greater hazard and that the use of wristlets is the safest and most effective alternative.

(6) The other end of the retrieval line shall be attached to a mechanical device or fixed point outside the permit space in such a manner that rescue can begin as soon as the rescuer becomes aware that rescue is necessary. A mechanical device shall be available to retrieve personnel from vertical type permit spaces more than 5 feet (1.52 m) deep.

h. Attendant(s):

(1) To be trained and to understand the hazards that may be present during entry. Reads and signs the permit [29CFR 1910.146(j)(4)].

(2) For proper use of equipment specified as required by the confined space permit.

(3) To stay in constant communication with the entrant.

(4) Recognizes hazards within and near the confined space and directs the entrant to leave the confined space if a new hazard is identified.

(5) Directs the attempt to retrieve the entrant from outside the confined space.

The attendant is to NEVER ENTER a confined space to try to rescue a worker.

(6) Remains on site and in communication with authorized entrant until the confined space entry permit is complete

i. Non-Entry Rescue Team is responsible:

(1) Rescue Team members must be successfully trained and proficient as an authorized entrant pursuant to 29 CFR 1910.146 paragraphs (g) and (h).

(2) Be trained in basic first-aid and cardiopulmonary resuscitation (CPR) with a current certification.

(3) Is equipped for and proficient in performing the needed rescue services.

(4) Practice making permit space rescues at least once every 12 months, by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces. Representative permit spaces shall, with respect to opening size, configuration, and accessibility, simulate the types of permit spaces from which rescue are to be performed.

(5) To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.

(6) Calls emergency medical services as needed if an entrant has an accident where medical assistance is needed.

5. Procedures:

a. A confined space entry form must be complete prior to entry into a confined space. The form must be requested through the Chief, Engineering Service. The form permit section must be completed prior to Chief, Engineering Service, or COTR authorization.

b. The following areas are designated as a confined space as defined under 29

CFR 1910.146:

(1) Permit required

(a) Manholes

(b) Sumps

(c) Elevator pits 1, 4 and 5

(d) Boiler Drum and Fire Box

(e) Tanks

(2) Non-Permit

(a) Building perimeter tunnels

(b) Dirt crawl spaces

(c) Elevator rooms 2 and 3

(d) Piping and Ventilation Shafts

(e) Ducts

c. Signage: All listed confined space requiring a confined space permit shall be clearly posted. Signs shall include as a minimum:

DANGER

CONFINED SPACE

AUTHORIZED PERSONNEL ONLY

(ANY SPECIAL REQUIREMENTS)

d. Medical Surveillance:

(1) Annual Physical, is required and may include:

(a) General evaluation of employee’s physical and psychological ability for working in a Confined Space.

(b) Ability to wear Personal Protective Equipment.

(c) Ability to hear, see, or feel warning/alarm systems.

(2) Medical follow-up to accidental exposure to a health hazard.

e. Training: All personnel entering a Confined Space shall be trained on the hazards associated with that space and acquire the understanding, knowledge, and skills necessary for the safe performance of duties assigned in that area.

Training shall be provided by the area supervisor or Industrial Hygienist and documented.

(1) Initial training will include, at minimum:

Review of the OSHA standard:

The VAMC Confined Space Program

- Review of key elements of the program

- Definitions of Confined Space

- Entry Checklist/Permit

- Air testing

- Energy neutralization (lockout/tagout)

- Authorized entrants

- Duties of attendants

- Entry Supervisor’s Role

- Special permits i.e., hot work

- Rescue

- Training requirements

- Hazards Found in Confined Spaces

- Air Monitoring Equipment

- Combustible gas/oxygen meter

- Confined Space Entry Equipment and Protective Clothing

- Rescue Methods and Techniques

- Hands-On Use of Equipment

f. Retraining: will be provided every annually for Entrants, Attendants, and Entry Supervisors and when:

(1) There is a change in permit space operations that present a new hazard; or

(2) There is reason to believe that there are deviations to or inadequacies with the permit system or procedures.

g. Confined Space Standard Operating Procedures (Attachment 2).

6. REFERENCES: 29 CFR 1910.146

7. RECISSION: Memorandum No. 138-12, dated June 2, 2011.

8. FOLLOW-UP RESPONSIBILITY: Chief, Engineering Service

9. AUTOMATIC RESCISSION: January 2, 2022

Arthur G. Ontto Jr, P.E., CHFM Chief, Engineering Service

Attachments

1. Confined Space Entry Permits

SOP 138-12-11 Attachment 1