Attachment 3 - EC-26 Confined Space.docx

CONFINED SPACE

1. PURPOSE: To establish policy and procedures for a Confined Space Protection Program.

2. POLICY: To provide and maintain an effective and comprehensive Confined Space Protection Program in accordance with Title 29, Code of Federal Regulations (CFR), 1910.146.

3. DEFINITIONS:

A. Atmospheric Testing: The testing of gases, vapors, mists and dusts within a confined space.

B. Attendant: An employee stationed outside the PERMIT REQUIRED Confined Space, who has been trained as required and who monitors the Authorized Entrants inside the permit required confined space.

C. Authorized Entrant: An employee or other worker who is authorized by an approved permit to enter a regulated confined space.

D. Confined Space: An enclosed area which has the following characteristics: Its primary function is something other than human occupancy, such as storage tanks, pits, sewers, pipelines, boilers, incinerators and deep trenches. OSHA defines three (3) types of confined spaces:

1) NON-PERMIT CONFINED SPACE: No hazard exists. (Must be documented).

2) CONTROLLABLE ATMOSPHERIC HAZARDS ONLY CONFINED SPACE: The only hazards are atmospheric (not enough oxygen, potential air contamination, potential flammable gas present, etc.) and by using forced ventilation alone, these hazards can be controlled. (These are areas that if certain controls are in place and documentation is on file, no permit is required.)

3) PERMIT REQUIRED CONFINED SPACE: Hazards may include dangerous air contamination; engulfment condition; entry/exit access; entrapment conditions, recognized serious safety or health hazards, etc., which require use of air monitoring equipment, ventilation equipment and special procedures when working in the area.

E. Entry Permit: The written authorization and evaluation of the confined space. The entry permit defines the conditions under which the permit space may be entered.

F. Entry Supervisor: An employee who ensures that all equipment needed for safe entry is available. Is knowledgeable of the hazards associated with the confined space; verifies acceptable entry conditions; signs the permit and cancels any permits when unsafe conditions are identified.

G. Hazardous Atmosphere: Conditions that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue, injury or acute illness. This may be due to flammable gases, vapors or mists; airborne concentrations of dusts that exceed the lower flammable limit; atmospheric oxygen concentrations below 19.5% or above 23.5%; atmospheric concentration of any substance for which a dose or permissible exposure limit that could result in an employee exposure as defined in Subpart G, Occupational Health and Environmental Control, or in Subpart Z, Toxic and Hazardous Substances of this part or any atmospheric condition that is immediately dangerous to life or health.

H. Rescue Team: Initial responder is the Entry Attendant. The Entry Attendant will radio the Fargo VA Health Care System Police Officer on-duty who will call the Fargo Fire Department (9-911). The Fargo Fire Department is trained in Confined Space Rescue and evaluates/trains in the confined spaces at Fargo VA Health Care System on a regular basis.

4. RESPONSIBILITIES:

A. Chief, Engineering Service, will:

1) Maintain a confined space program to ensure employee safety.

2) Establish a written permit system for the proper preparation, issuance and implementation of entry permits.

B. Industrial Hygiene & Safety Manager (IH & S) will:

1) Review Circular EC-26, Confined Space, and confined space procedures annually.

2) Determine needs and provide annual training to ensure the safety of employees.

3) Provide technical expertise for confined space procedures.

4) Provide atmospheric monitoring as needed.

5) Conduct a survey of all premises and/or operations to identify confined space areas where confined space regulations must be followed. (PERMIT REQUIRED CONFINED SPACE.)

6) Place warning signs “DANGER, CONFINED SPACE, Enter By Permit Only” where designated.

7) Identify confined spaces which, after evaluation, have been found to have little potential for generation of hazards or the hazards have been eliminated by engineering controls. (NON-PERMIT REQUIRED CONFINED SPACE.)

8) Revoke any confined space permit if hazardous conditions or work activity that could cause hazardous conditions exist.

C. Engineering Service personnel will:

1) Attend annual confined space training.

2) Complete the Confined Space Entry Pre-Checklist and Permit before work is initiated. (Attachments A and B)

3) Ensure that personal protective equipment for confined space is available and properly maintained in order to sustain the original amount of protection afforded by the equipment.

4) Ensure the proper care, use and maintenance of the confined space protection equipment. The employee will report any problems with the equipment to the immediate supervisor.

5) Assist contractors entering VAHCS confined spaces with required permitting.

5. PROCEDURES:

A. Identified Confined Spaces:

1) Areas/Operations which are considered to be PERMIT REQUIRED Confined Space entry are cleaning of boilers, sewer ejector pit maintenance, sewer manholes, electric manholes/vaults (under transformers), dike pump pit and water meter pit. Areas/Operations which are PERMIT REQUIRED Confined Space may be evaluated and determined, due to engineering controls and pre-atmospheric testing, to be considered as non-hazardous to the worker and NON-PERMIT REQUIRED Confined Space.

2) Areas/Operations which are considered NON-PERMIT REQUIRED Confined Spaces are pipe basements, laundry crawl space, warehouse crawl space and HVAC air handlers.

B. Training:

1) All Engineering Service employees involved in confined space entry will receive training:

a) Before the employee is first assigned duties for confined space entry.

b) When there is a change in assigned duties.

c) Annually.

d) Whenever there is a change in permit space operations that presents a hazard which an employee has not previously been trained.

e) When the employee has a reason to believe that there are deviations from the permit space entry procedures require by the OSHA regulation or inadequacies in knowledge or use of the confined space procedures.

f) When the permit is issued.

g) On each individual confined space specific procedures.

2) Training will consist of:

a) Overview of confined space policy;

b) Confined space definitions;

c) Areas of confined space;

d) Hazards of confined space;

e) Permit system;

f) Required duties of personnel (Entrant, Attendant, Supervisor);

g) Emergency Response Plan (Initial and Secondary Rescue); and,

h) Contractors.

3) Training for specific duties:

a) Authorized Entrant:

(1) Know confined space hazards, including information on the mode of exposure, signs or symptoms and consequences of the exposure.

(2) Maintain communication with the attendant to enable the attendant to constantly monitor the status of the entrant within the space and alert the entrant of the need to evacuate the space.

(3) Alert the attendant whenever the entrant recognizes any warning signs or symptoms of exposure to a hazardous situation or detects a prohibited condition.

(4) Exit from the confined space as soon as possible whenever the entry supervisor or attendant orders evacuation of the space; the audible alarm on the continuous monitor is activated; the entrant detects a prohibited condition or the entrant recognizes any warning sign or symptom of exposure to a hazardous situation.

(5) Use appropriate personal protective equipment properly.

b) Attendant:

(1) Knows existing potential hazards, including information on the mode of exposure, signs or symptoms, consequences of the exposure and their physiological effects.

(2) Knows of possible behavioral effects of hazard exposure in entrants.

(3) Remains outside of the space and communicates with the entrants as necessary to monitor their status.

(4) Continuously maintains an accurate account of the authorized entrants in the confined space.

(5) Remains outside the confined space during entry operations until relieved by another attendant.

(6) Communicates with the entrant(s) as necessary to monitor entrant status and to alert entrant of the need to evacuate the space.

(7) Monitors the activities inside and outside of the space to determine if it is safe for the entrant(s) to remain in the space.

(8) Orders entrant(s) to evacuate the space under the following conditions:

(a) The attendant detects a prohibited condition;

(b) The attendant detects a situation outside the space that could endanger the entrant;

(c) The attendant cannot effectively and safely perform all the duties as required by this policy.

(9) Summons the Fargo VA Health Care System Police Officer and Fargo Fire Department (9-911) if it is determined that entrant(s) may need assistance to escape from hazards within the confined space.

(10) If unauthorized persons approach or enter a confined space when entry is underway:

(a) Warns unauthorized persons to stay clear of the confined space and the immediate area;

(b) Advises the unauthorized person that they must exit immediately; and,

(c) Informs the entrant and entry supervisor if unauthorized persons have entered the confined space.

(11) Refrains from engaging in any activities that would divert attention from the ability to monitor and protect workers in the space.

(12) Performs non-entry rescues only.

c) Entry Supervisor:

(1) Knows the hazards that may be faced during entry, including information on the mode, signs or symptoms and consequences of the exposure.

(2) Verifies that the permit is completed and there are no items left undone. Verifies all equipment specified in the permit is in place before allowing the entry to begin.

(3) Terminates the entry and cancels the permit when: the entry operations covered by the entry permit have been completed or conditions arise that are not covered under the permit.

(4) Verifies that rescue services are available and means for summoning them are operational.

(5) Arranges to remove unauthorized individuals who enter or attempt to enter the confined space during entry operations.

(6) Determines that entry operations remain consistent with the terms of the entry permit and acceptable entry conditions are maintained.

C. Permit Procedures:

1) Engineering Service personnel who have been fully trained in working in confined spaces and personal protective equipment will be issued permits authorizing them to work in confined spaces.

2) A Confined Space Entry Permit will be completed before each entry is made into any confined space. Each permit will contain the following:

a) A description of the permit space.

b) The purpose of entry.

c) The date and duration of the permit.

d) Identification of employees who are authorized to enter.

e) Identification of employees acting as attendants stationed outside the permit space and responsible for monitoring the employees inside the space, etc.

f) Identification of the entry supervisor, who will authorize the entry after reviewing the permit. (Signature required.)

g) The hazards of the permit space to be entered.

h) Methods used to eliminate or control the space hazards before entry.

i) A list of equipment to be used such as personal protective equipment, testing equipment, communication equipment and alarm equipment.

j) Results of the atmospheric testing requirements, with the name of the individual performing the testing, and the indication of when the tests were performed.

k) Communication procedures used by the authorized entrant and attendants to maintain contact during the entry.

l) Signature of supervisor authorizing the entry.

3) The permit will be completed by a qualified person in Engineering Service, and the contents communicated to all workers and posted at the work site.

4) The IH & S Manager or Entry Supervisor will revoke any permit when conditions and/or work activity are different than those specified on the permit and could introduce a new hazard to the confined space.

5) Isolation and lockout/tagout procedures will be adhered to. All energy sources which are potentially hazardous to confined space entrants will be secured, relieved, disconnected and/or restrained before personnel are permitted to enter a confined space.

6) Hot work permits will be required if any welding or soldering is needed inside the confined space.

7) Permits, cancelled or completed, will be retained for at least one (1) year in order to review the confined space program. Any problems encountered will be noted on the specific permit in order to make appropriate changes to the permit required confined space.

D. Pre-Entry Atmospheric Testing Procedure:

1) Confined space to be entered will be ventilated before confined space entry is authorized.

2) The atmosphere in the confined space will be tested to evaluate the hazards and to verify that acceptable entry conditions exist.

3) Atmospheric testing instruments will be calibrated in compliance with manufacturer's instructions.

4) Chief, Engineering Service, will designate an employee to conduct pre-entry atmospheric testing.

5) The minimum acceptable air quality standards prior to confined space entry will be:

a) Oxygen level: Not less than 19.5 percent by volume nor greater than 23.5 percent by volume. Oxygen enriched atmospheres can promote explosions occur due to sparks.

b) Combustible gas: Concentration will not exceed ten (10) percent of the lower explosive limit (LEL) of any combustible material existing or introduced into the confined space.

c) Toxic substances: Determined by the employer, concentration will not exceed toxic guidelines, which constitute a threat of death, injury, acute illness or disablement.

6) Prior to each confined space entry, the atmosphere will be tested quantitatively for the minimum acceptable levels as stated above with an appropriate direct reading device. The space will be tested first for oxygen percentage then carbon monoxide, hydrogen sulfide and combustible gases.

7) The confined space will be continuously tested for atmospheric conditions while the authorized entrant is in the confined space.

8) When ten (10) percent or more of the LEL of combustible gas is detected in any confined space, steps will be taken to improve ventilation or reduce contaminants and increase frequency of gas testing to ensure improvement of the air quality.

9) Hot work will not proceed in any confined space when the atmospheric level of a combustible gas exceeds 10 percent of the LEL.

10) When 20 percent or more of the LEL of combustible gas is detected in any confined space work procedure:

a) All employees except those necessary to eliminate the hazard will exit to a safe location.

b) All electrical apparatus except that certified as intrinsically safe or explosion proof will be disabled or removed until gas concentration has been reduced to less than 20 percent of the LEL.

E. Emergency Services:

1) In the event of an emergency, the Attendant will summon rescue and other emergency services by two-way radio to the Fargo VA Health Care System Police Officer on duty.

2) Police Officer will alert the Fargo Fire Department (9-911).

3) Entry Attendant will provide non-entry rescue ONLY.

F. Contractors will only perform Confined Space Entry under the direct supervision of an Engineering Service employee. All procedures listed above will be completed by the contractor. An Engineering Service employee will remain with the contractor at all times while confined space entry is being performed.

6. RECORDS MANAGEMENT: All records regardless of format (paper, electronic, electronic system) created by this directive will be managed per National Archives and Records Administration (NARA) approved records schedules found in VA Records Control Schedule 10-1. Questions regarding any aspect of records management will be addressed to the facility Records Manager or Records Liaison.

7. REFERENCES:

29 CFR 1910.146, Confined Space Center for Engineering, Occupational Safety and Health (CEOSH), Industrial Hygiene Guidebook

8. RESPONSIBILITY: Chief, Engineering Service (138), is responsible for the contents of this circular.

9. RESCISSION: Circular EC-26 dated May 10, 2016

10. REVIEW DATE: May 2022

B: Combined Space Entry Permit

Distribution: Alluser drive :

CONFINED SPACE ENTRY PRE-CHECKLIST

Do not enter a confined space until you have determined the space to be safe.

Yes No [ ] [ ] Is entry necessary?

Hazards Associated with Work to be Performed

[ ] [ ] Will there be burning, welding, brazing or open flame in confined space?

[ ] [ ] Will chemicals, solvents, steam or sandblasting be used for cleaning?

[ ] [ ] Will coating be applied/repaired in confined space?

Cleaning

[ ] [ ] Has the space been cleaned before entry is made?

[ ] [ ] Was the space steamed?

[ ] [ ] If so, was it allowed to cool?

Isolation

[ ] [ ] Has the confined space been drained, flushed or purged?

[ ] [ ] Have all breakers, switches, drive mechanisms, valves, vents and drains been tagged/locked out?

[ ] [ ] Have lines under pressure been blanked and bled?

Testing

[ ] [ ] Are the instruments used in atmospheric testing properly calibrated?

[ ] [ ] Was the atmosphere in the confined space tested?

[ ] [ ] Was oxygen at least 19.5% - not more than 23.5%?

[ ] [ ] Were toxic flammable or oxygen-displacing gases/vapors present?

Monitoring

[ ] [ ] Will the atmosphere in the space be monitored while work is going on?

[ ] [ ] Continuously?

[ ] [ ] Periodically? (If yes, how often ________________________?)

Respiratory Protection

[ ] [ ] Is respiratory protection required?

[ ] [ ] Can you get through the opening with a respirator on? (Perform entry)

Ventilation

[ ] [ ] Has the space been ventilated before entry?

[ ] [ ] Will ventilation be continued during entry?

[ ] [ ] Is the air intake ventilation system located in an area that is free of combustible dusts and vapors and toxic substances?

[ ] [ ] If atmosphere was found unacceptable and then ventilated, was it re-tested before entry?

Standby

[ ] [ ] Will there be standby person on the outside?

[ ] [ ] Will standby person be able to see or hear the person inside at all times?

[ ] [ ] Will safety lines and harness be required to remove procedure?

[ ] [ ] Do you know who to contact and how in the event of an emergency?

Clothing/Equipment

Training

[ ] [ ] Have you been trained in confined space entry?

[ ] [ ] Have you been trained in emergency procedures?

Permit

[ ] [ ] Has a confined space entry permit been issued? Date_________

CONFINED SPACE ENTRY PERMIT

CONFINED SPACE NO. ___________________________________ LOCATION _______________________________________

WORK ORDER NO. _______________________________________ PURPOSE OF ENTRY _____________________________

Is Entry Necessary: Yes_________ No:__________

Atmospheric Recheck (immediately prior to entry)

RESCUE TEAM AVAILABLE: Yes No

PERMIT IS GOOD ONLY FOR THE DATE LISTED ABOVE

TIME ENTERED: ________ TIME EXITED:_________

CONFINED SPACE ENTRY PERMIT

Other ( ) ( )

Pre-Entry Atmospheric Monitoring Performed by:

Pre-Entry Check List Performed by:

RELEASE TO NON-PERMIT (NPCS) STATUS

Evaluation Summary

Action to eliminate hazard(s):

Certification of Hazard(s) Elimination:

Entry Supervisor’s Signature

Auth. Entrant(s):

Entry Supervisor:

Other:

Other:

Debriefing Remarks:

Entry Supervisor’s Signature: