Confined Space Entry.docx

SUBJECT: Confined Space Entry

A. PURPOSE: To provide a safe working environment for employees engaged in maintenance, repair and inspection of interior areas of boilers, ventilation and exhaust ducts, tanks, pits, manholes, utility vaults and other identified confined spaces.

B. POLICY: It is the policy of this Medical Center to establish procedures that comply with OSHA Standard 29 CFR 1910.146 which defines confined space requirements. This policy shall be followed by all employees who work in a permit-required confined space.

C. SCOPE: The policy shall prevent unauthorized employee entry and ensure safe entry into and work within permit required confined spaces.

D. PROGRAM ELEMENTS:

1) Hazard Evaluation: Spaces shall be evaluated to determine if they are confined spaces. Additional evaluation is needed to determine if the space is considered a permit required confined space. Confined spaces determined to be a permit-required confined space shall be marked/labeled with a sign that reads as follows: “Danger – Confined Space, Enter by Permit only” or other similar language.

2) Permit Program:

a) All permit-required confined spaces shall be entered following the proper steps, which are outlined in the written procedures. The proper signatures will be noted on the forms.

i) Permits are to be obtained from the Supervisor (or designee) or Safety Technician. The permit shall be posted at the space while the work is being performed.

ii) Before entry, the air shall be monitored to ensure a safe environment. The air shall be continuously monitored after entry. The following shall be tested before entry, using properly calibrated monitoring equipment:

(1) Oxygen content greater than 19.5% and less than 23.5%.

(2) %LEL (Lower Explosive Limit) which detects an explosive or combustible atmosphere.

(3) Hydrogen Sulfide or other identified potential toxic air contaminant(s).

(4) Air monitoring shall be done following the specific written procedures for the permit space.

(a) If any of the following occur, entry into a confined space shall not be allowed:

· Audible alarm and/or flashing light on the monitoring device are activated.

· Work to be performed is not specified in procedures for the space.

· A condition arises in or near the permit space that is not allowed by the permit and/or procedures.

(i) NOTE: If any of the above occurs, the space shall not be entered and the permit shall be cancelled by the entry supervisor. If any of the above occurs during entry, the space shall be evacuated immediately and the permit shall be cancelled by the entry supervisor. The space shall not be entered until it can be determined why one of the above occurred and the space can be cleared to enter. All cancelled permits shall maintained by Shop Supervisor.

(2) If there is the potential that a hazardous atmosphere could exist in a confined space then the space must be adequately ventilated prior to entering. Follow the specific procedures developed for each space. Fresh air can be provided by the use of a portable air blower or fan. When possible, a hose shall be used to direct the fresh air from the blower to the immediate area where the entrant(s) will be working.

(3) CAUTION: Never use pure oxygen to ventilate a space. An oxygen rich atmosphere contains the potential to burn violently.

b) When welding is to be done in a confined space, a Hot Work Permit shall be obtained from Facilities Engineering Service.

i) When welding in confined spaces:

(1) Gas cylinders and welding machines shall be located outside the confined space and at least 20 feet from the entry.

(2) The confined space must be ventilated. Oxygen shall never be used for ventilation.

(3) The welder must wear a safety belt and a lifeline when working in a confined space.

(4) During suspensions in welding operations, i.e., lunch time or overnight, etc., all electrodes will be closed and the torch and hose assembly will be removed from the confined space.

c) All equipment needed to enter a confined space will be located and assembled on site. Equipment will be checked in after every use.

d) Portable electric tools, equipment, and lighting shall be equipped with ground fault interrupter (GFI) if the equipment is going to be used in the confined space.

e) Personal protective equipment (PPE) shall be approved for use in confined spaces. The following are some examples of PPE that may be necessary for entry into a confined space:

i) Safety goggles.

ii) Face shield.

iii) Hard hat.

iv) Explosion proof lighting/low voltage.

v) Ear plugs.

vi) Rubber boots.

vii) Gloves-rubber, leather.

viii) Respiratory protection.

f) The following programs shall be incorporated when the procedure requires their use:

i) Lock out procedures.

ii) Hot work permit.

iii) Respirator program.

iv) Emergency response program.

2) Non-Permit Program:

a) List of identified non-permit required confined spaces shall be reviewed annually.

b) Non-permit confined spaces shall be reevaluated when new work practices or conditions are required (i.e. welding in the space) to determine if the new activity/condition requires the space to be re-classified as a permit-confined space.

3) Entry Permit details as follows:

a) The supervisor in charge of authorizing the permit shall issue the permit the day the entry is to occur (as close to the entry time as possible). After the completion or expiration of a permit, the original shall be filed with the Shop Supervisor. Permits shall be kept on file for at least two (2) years. All cancelled permits shall be returned to the Shop Supervisor.

b) The following conditions would constitute a cancellation of a permit entry:

i) An audible alarm and/or flashing light on the monitoring device are activated.

ii) A condition arises inside or outside of the space that could endanger the entrants.

iii) Entrants notice changes within themselves (fatigue, dizziness, nausea, etc.).

iv) Any other condition that may occur that is not covered by the permit for that space.

c) Cancelled permits shall constitute a re-evaluation of the space to determine if added precautions are necessary to complete an entry.

d) An entry permit shall be required whenever a part of the body would enter the confined space.

e) The entry permit shall include the following information:

i) Identity of the permit space to be entered.

ii) The purpose of entry.

iii) The date and time entry is to be made and authorized duration for which the permit is valid (expiration date). A permit is valid for only how long the job is to last. The permit must cease when the duration time is met.

iv) The name of the person supervising and authorizing the permit.

v) The authorized entrants by name.

vi) The authorized attendants by name.

vii) The individual, by name, currently serving as entry supervisor, with a space for the signature or initials of the entry supervisor who originally authorized entry

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

ix) The measures used to isolate the permit space and to eliminate or control permit space hazards before entry.

x) Acceptable entry conditions.

xi) The results of the initial and periodic tests performed, which have the initials of the person taking the tests immediately after them.

xii) Rescue and emergency services and contact numbers and the means for summoning those services (such as the equipment to use and the numbers to call).

xiii) The communication procedures used by authorized entrants and attendants to maintain contact during the entry.

xiv) Equipment, such as personal protective equipment, testing equipment, communications equipment, alarm systems, and rescue equipment, to be provided for compliance with this section.

xv) Any other information, including other permits (Hot Work Permits) and information which may be needed to ensure employee safety.

4) Permit Required Confined Space Program Elements:

a) Hazard Identification: Identify and evaluate each hazard of the permit spaces, including determination of severity.

b) Hazard Control: Establish and implement the means, procedures and practices by which the permit spaces can be entered safely.

c) Permit System: Establish a written permit system for the proper preparation, issuance, and implementation of entry permits.

d) Employee Information: Permits shall be posted near permit spaces to notify employees of the possible hazards that may be present and that only authorized entrants are allowed to enter those spaces.

e) Prevention of Unauthorized Entry: Prevent unauthorized employee entry through such measures as training or by posting signs and barriers, as necessary.

f) Employee Training: Train employees, as provided by this standard, so that attendants, authorized entrants and personnel authorizing or in charge of entry can work safely in and around the permit space.

g) Equipment: Provide, maintain, and ensure the proper use of the equipment necessary for safe entry, including testing, monitoring, communication, and personal protective equipment.

h) Rescue: Ensure that the procedures and equipment necessary to rescue entrants from permit spaces are implemented and provided.

i) Protection from External Hazards: Ensure that all pedestrian, vehicle, or other barriers necessary to protect entrants from external hazards are provided.

j) Duty to Outside Contractors: Ensure that when an outside contractor is going to be entering a permit required confined space, the Minneapolis VA Health Care System (MVAHCS) provides the contractor with all available information on the permit space hazards. The MVAHCS shall also provide all safety rules and emergency procedures to the contractor that apply to the work being performed at the permit required confined space location.

E. PROCEDURES:

1) Confined Spaces: A list of non-permit and permit required confined spaces shall be maintained by Facilities Engineering. Classification will be determined by Facilities Engineering, the Safety Department is available for consultation; those currently identified include but are not limited to:

a. Permit Required Confined Spaces:

· Manholes throughout facility: sewer, storm, electrical, and steam.

· Boilers 1, 2, 3 & 4: steam drum, mud drum, and fire box in the Energy Center (#69)

· Make up tank, #69

· Deaerator tank, #69

· Blow down tanks, #49 & #69

· Tower cooling pit, #69

· Trash Chutes throughout facility

· Well Water Storage Tank, #70

· Trash Pump Pit, #70

b. Non-Permit Confined Spaces:

· Air handlers throughout facility

· HVAC duct work throughout the facility

· Elevator Shafts/Pits throughout facility

· Elevator Mechanical Room pits

· Steam Tunnel, #69/#70

2) Permit-Required Confined Space Entry:

a) Notification of planned entrance shall be given to the Shop Supervisor, if lead time is available, 24-hours advanced notice should be given.

b) Permits must be accurately and completely filled out prior entering the permit required confined space. Permits are valid for only the time specified on the permit. If work is carried over multiple shifts new permits must be issued.

c) Personnel must be assigned to the following positions prior to entry: Entrant, Attendant and Supervisor responsibilities must be identified.

d) Entry procedures specific to the space to be entered must be reviewed with all staff.

e) Proper equipment to protect entrants and other employees (e.g. PPE, rescue equipment, communication equipment, lighting, barriers, etc.) must be obtained prior to entering the space. The equipment must be inspected and tested to verify it is in good working condition prior to entry.

f) Rescue procedures must be reviewed prior to entering space. Ensure all necessary notifications are made and documented on the permit (e.g. notification to Fire Department).

a. Notification shall be made to the Miineapolis Fire Department of the date, expected time in the confined space and the type of work to be completed.

(612) 348-2821 - Dispatch Number:

g) Ensure space is isolated and properly purged and/or ventilated.

h) Entry into any type of permit-required confined space is prohibited until initial testing of the atmosphere in the space has been completed from outside the space.

a. Air monitoring data, from the interior of the permit-required confined space, must be listed on the permit and must fall within the required limits:

i. Oxygen level between 19.5% and 23.5%.

ii. Lower flammable limit less than 10%.

iii. Carbon monoxide level lower than 35 PPM (parts per million).

iv. Hydrogen sulfide level below 10 PPM.

b. If one of the levels is not met, entry into the confined space is prohibited.

c. Continue with continuous monitoring, periodic sampling data (every two hours) must be recorded on the permit.

i) All entry criteria must be met prior to entrance.

j) Ensure Attendant is in place prior to entrance.

k) The entry permit shall be signed by the Supervisor and Safety Manager or Safety Technician.

l) Once work is completed, or the entry has been canceled, the Supervisor shall terminate the permit. The Shop shall retain a the permit in their records.

F. TRAINING REQUIREMENTS:

1) Training shall be provided to each affected employee: prior to being assigned duties involving a permit-required confined space; prior to a change in assigned duties; whenever there is a change in permit space operations that presents a hazard about which an employee has not previously been trained; whenever the employer has reason to believe either that there are deviations from the permit space entry procedures or that there are inadequacies in the employee's knowledge or use of these procedures.

a) Duties of Authorized Entrant:

i) Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure;

ii) Know how to properly use equipment (e.g. communication, personal protective, self rescue);

iii) Communicate with the attendant as necessary to enable the attendant to monitor entrant status and to enable the attendant to alert entrants of the need to evacuate the space if required;

iv) Alert the attendant whenever:

(1) The entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or

(2) The entrant detects a prohibited condition; and

(3) Exit from the permit space as quickly as possible whenever

(a) An order to evacuate is given by the attendant or the entry supervisor,

(b) The entrant recognizes any warning sign or symptom of exposure to a dangerous situation

(c) The entrant detects a prohibited condition, or

(d) An evacuation alarm is activated.

b) Duties of Attendant(s):

i) Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure;

ii) Is aware of possible behavioral effects of hazard exposure in authorized entrants;

iii) Continuously maintains an accurate count of authorized entrants in the permit space and ensure that the means used to identify authorized entrants accurately identifies who is in the permit space;

iv) Remains outside the permit space during entry operations until relieved by another attendant; NOTE: attendants may enter a permit space to attempt a rescue if they have been trained and equipped for rescue operations and if they have been relieved as required.

v) Communicate with authorized entrants as necessary to monitor entrant status and alerts entrants of the need to evacuate the space;

vi) Monitor activities inside and outside the space to determine if it is safe for entrants to remain in the space and orders the authorized entrants to evacuate the permit space immediately under any of the following conditions;

(1) Prohibited condition is detected;

(2) Detects the behavioral effects of hazard exposure in an authorized entrant;

(3) A situation outside the space could endanger the authorized entrants; or

(4) If he/she cannot effectively and safely perform all the duties required by the attendant (e.g. starts to feel ill);

vii) Know how to summon rescue and other emergency services as soon as the attendant determines that authorized entrants may need assistance to escape from permit space hazards;

viii) Know to take the following actions when unauthorized persons approach or enter a permit space while entry is underway:

(1) Warn the unauthorized persons that they must stay away from the permit space;

(2) Advise the unauthorized persons that they must exit immediately if they have entered the permit space; and

(3) Inform the authorized entrants and the entry supervisor if unauthorized persons have entered the permit space;

(4) Performs non-entry rescues as specified by the employer's rescue procedure; and

(5) Performs no duties that might interfere with the attendant's primary duty to monitor and protect the authorized entrants.

c) Shop Foreman/Supervisor authorizing or in charge of entry shall be trained in the following:

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

ii) Verifies, by checking that the appropriate entries have been made on the permit, that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin;

iii) Terminates the entry and cancels the permit as required by paragraph (e)(5) of this section;

iv) Verifies that rescue services are available and that the means for summoning them are operable;

v) Removes unauthorized individuals who enter or who attempt to enter the permit space during entry operations; and

vi) Determines, whenever responsibility for a permit space entry operation is transferred and at intervals dictated by the hazards and operations performed within the space that entry operations remain consistent with terms of the entry permit and that acceptable entry conditions are maintained.

2. Contractors shall be informed by the Facilities Engineering Service, Project Section/designee that they are going to be working in a confined space and that entry is allowed only through compliance with the MVAHCS Confined Space program. MVAHCS shall apprise the contractor of the elements, including the hazards identified and our experience with the space, that make the space in question a permit space and any precautions or procedures implemented for the protection of employees in or near the permit confined spaces where contractor personnel will be working. The contractor shall follow all procedures established for the space. The contractor will provide all equipment necessary for entry into the permit space. The contractor shall also be responsible for providing confined space entry training to their employees. The contractor shall debrief the facility at the conclusion of the entry operations regarding the permit space program followed and regarding any hazards confronted or created in permit spaces during entry operations.

G. REFERENCES: OSHA 29 CFR 1910.146; Permit-Required Confined Spaces, 1992

H. RESCISSION: Facilities Engineering Memorandum Number 37, Confined Space 22 February 2021.

I. FOLLOW-UP RESPONSIBILITY: Safety Manager

STEVE CHALLEEN

Director, Facilities Engineering Service

Veterans Affair Medical Center, Minneapolis, MN Date: July 1, 2022

Facilities Engineering Service MEMORANDUM NO: 37 Attachments: Confined Space Definitions, Plant Systems & Engineering and Confined Space Entry Permit Form

Confined Space - Definitions

Acceptable Entry Conditions: The conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permit required confined space entry can safely enter into and work within the space.

Attendant: An individual stationed outside one or more permit spaces who monitors the authorized entrants and who performs all attendant's duties assigned in the employer's confined space entry.

Authorized Entrant: An employee who is authorized by the employer to enter a permit space.

Blanking or Blinding: The absolute closure of a pipe line or ducts by the fastening of a solid plate that completely covers the bore and that is capable of withstanding the maximum pressure of the pipe, line or duct with no leakage beyond the plate.

Confined Space: 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 are spaces that may have limited means of entry); and

· is not designed for continuous employee occupancy.

Emergency: Any occurrence (including any failure of hazard control or monitoring equipment) or event internal or external to the permit space that could endanger entrants.

Engulfment: The surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system, or that can exert enough force on the body to cause death by strangulation, constriction or crushing.

Entry: The action by which any part of a person passes through an opening into a permit-required confined space and that contains the information specified in the definition "confined space".

Entry Permit: The written or printed document that is provided by the employer to allow and control entry into a permit-required confined space.

Entry Supervisor: The person responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry, for overseeing entry operations, and for terminating entry. The entry supervisor may also serve as an attendant or authorized entrant. Duties of the entry supervisor may be passed from one individual to another during the course of an entry operation.

Hazardous Atmosphere: An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self rescue, injury, or acute illness from one or more of the following causes:

1) Flammable gas, vapor, or mist in excess of 10 percent of its lower flammable limit (LFL).

2) Airborne combustible dust at a concentration that meets or exceeds its LFL (may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (l.52 m.) or less).

3) Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent.

4) Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published by OSHA, or contained on the MSDS.

Hot Work Permit: The employer's written authorization to perform operations (for example, riveting, welding, cutting, burning and heating) 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 that would cause irreversible adverse health effects, or that would interfere with an individual's ability to escape unaided from a permit space.

Inerting: The displacement of the atmosphere in a permit space by a non combustible gas (such as nitrogen) to such an extent that the resulting atmosphere is non-combustible.

Isolation: The process by which a permit space is removed from service and completely protected against the release of energy and material into the space.

Non-Permit Confined Space: A confined space that does not contain (with respect to atmospheric hazards) or have the potential to contain any hazard capable of causing death or serious physical harm.

Oxygen Deficient Atmosphere: An atmosphere containing less than l9.5 percent oxygen by volume.

Oxygen Enriched Atmosphere: An atmosphere containing more than 23.5 percent oxygen by volume.

Permit-Required Confined Space: A confined space that has one or more of the following characteristics:

1) Contains or has a potential to contain a hazardous atmosphere.

2) Contains a material that has the potential for engulfing an entrant.

3) Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or floors.

Prohibited Condition: Any condition in a permit space that is not allowed by the permit during the period when entry is authorized.

Rescue Service: The personnel designated to rescue employees from permit spaces.

Retrieval System: The equipment (including a retrieval line, chest or full-body harness, wristlets, if appropriate, and a lifting device or anchor) used for non-entry rescue of persons from permit spaces.

Testing: The process by which the hazards that may confront entrants of a permit space are identified and evaluated. Testing includes specifying the tests that are to be performed in the permit space.

1300:6108

PLANT SYSTEMS AND ENGINEERING

Attachment #B

Appendix A to 1910.146 -- Permit-required Confined Space Decision Flow Chart [Corrected by 58 FR 34845, June 29, 1993]

Yes

Consult other applicable OSHA

Yes

Stop

Inform employees as required by 1910.146 (c) (2).

Prevent employee entry as required by 1910.146 (c) (3).

Yes

Task will be done by contractors’ employees. Inform contractor as

No information required by 1910.146 (c) (9) (i), (ii), and (iii) from host.

Will host employees enter

No to perform entry tasks?

Yes

No

Coordinate entry operations as required by 1910.146

(c) (8) (iv) and (d) (11). Prevent unauthorized entry.

Yes does not apply. Consult other OSHA standards.

No

Stop1

No

Permit not valid

Prepare for entry via permit procedures.

until conditions meet permit

needed, rescuers/means to summon available, entrants properly equipped, etc.)

Yes

Emergency exists (prohibited condition).

entry conditions maintained throughout entry.

rescuers if needed). Permit is void.

Yes

Re-evaluate program to correct/prevent prohibited condition. Occurrence of

Entry tasks completed. Permit returned and canceled.

emergency (usually) is proof of deficient program. No re-entry until program (and

Audit permit program and permit based on evaluation of permit) is amended. (May require new entry by entrants, attendants, testers, and preparers, etc.

program.)

Continue

1 Spaces may have to be evacuated and re-evaluated if hazards arise during entry.

Permit-required Confined Space Entry Permit

1. Permit Conditions

Permit expiration (date and time):

Attendant(s):

See the Confined Space Inventory for the following information

Tracking number:

Known and potential hazards:

Additional required permits (for example hot work, radiological work permit, penetration permit):

Is notification of Rescue Service required? |_| YES |_| NO (Minneapolis Fire: DISPATCH: (612) 348-2821) Has the Rescue Service been notified? |_| YES |_| NO Date/Time:_________ Contact Name:_________________

2. Requirements Checklist (check all that apply)

Non-entry rescue equipment |_| Full body harness |_| Tripod / hoist |_| Lifeline Area security: |_| Warning signs |_| Barricades |_| Gloves: |_| Leather |_| Impervious |_| Chemical resistant |_| Other:

Face / eye protection: |_| Face shield |_| Goggles |_| Other:

|_| Fire extinguisher

|_| Head protection

3. Pre-entry Checklist

|_| Verify adequate confined space training |_| Pre-entry briefing on specific hazards and control methods |_| Notify subcontractors of permit and hazard conditions |_| Non-entry rescue and procedure in place |_| Notify affected departments and persons of service interruption |_| Lines blocked or broken |_| Drain space |_| Other:

Control of hazardous energy:

|_| Lockout / tagout (LOTO) |_| Zero-voltage verification (ZVV) |_| Other:

Communication: |_| Radio |_| Rope signals |_| Hand signals |_| Verbal Lighting: |_| Hazardous location rated |_| Standard Air flush: |_| Preliminary |_| Continuous |_| Other:

4. Personnel Entry and Exit Record (to be completed as needed before and during work)

Time in

Time out

Time in

Time out

Notes:

5. Air Monitoring Results (to be completed as needed before and during work)

Attendant will sample air |_| Continuously |_| Every ______ minutes |_| No sampling required because:

Device

Sequence or serial number

Date:

5. Air Monitoring Results (continued)

Time

(19.5–23.5%)

(LEL/LFL <10%)

|_| CO

(<25 ppm) |_| H2S (<10 ppm)

6. Pre-entry Certification (must be signed by the confined space Entry Supervisor before entry)

I hereby certify that all required hazard controls are in place, that air monitoring is being conducted as required and results show that the atmosphere is acceptable for entry, and that all required information is documented on this permit.

Confined space Entry Supervisor for this entry:

7. Permit Closure (must be signed by the confined space Entry Supervisor after work is completed)

The work was done in accordance with this permit. A copy of this permit will be forwarded to the confined space Program Manager

Name:

ATTENDANCE RECORD

Confined Space Training Memorandum No. 37

Date: Instructor: Location:

Start Time: End Time: #Attending:

Description of Event:

(Attendees shall read the Policy associated with Training.)

Print Name (First, Mi, Last)

Signature Initial Policy/Procedure was provided.

1. File: Hard Copy with Supervisor and TMS ADMIN.