Exhibit_1_-_HDP-06_-_Hoover_Dam_Confined_Space_Program.pdf

United States Department of the Interior

BUREAU OF RECLAMATION

Lower Colorado Dams Office P.O. Box 60400

Boulder City, NV 89006-0400

LCD-30000

3.1.03

HOOVER DAM PROTOCOL: HDP-06

To: All Hoover Dam Employees

From: Mark R. Cook Manager, Hoover Dam

Subject: Hoover Dam Confined Space Program

PURPOSE: The purpose of this protocol is to establish a uniform procedure for safe entry into confined spaces and ensure that proper protection is taken by all employees and contractors/subcontractors working in or near confined spaces. The Lower Colorado Dams Office (LCDO) Occupational Safety, Health and Environmental (OSHE) office will consult with affected employees and/or their authorized representatives on the development, maintenance, and implementation of all aspects of the HDCSP. Engineering and administrative controls shall be implemented to reduce confined space hazards whenever feasible.

SCOPE: This protocol pertains to all employees, contractors/sub-contractors who enter or work in or around confined spaces or supervise such activities within Hoover Dam and all associated facilities. It specifically discusses roles and responsibilities, training requirements, identifying permit required (PRCS) and non-permit required (NPRCS) confined spaces, the permit system, atmospheric testing, entry procedures, and rescue protocols.

EFFECTIVE DATE: This protocol is effective the date of this memorandum.

CANCELLATION: This protocol will remain in effect until superseded or cancelled in writing.

PROTOCOL:

A. PROGRAM ADMINISTRATION:

1. Table-1 provides the roles and contact information for the administration if the HDCSP.

Role Contact Information Area Office Manager (or Designee) 702-494-2301 OSHE Manager/Program Coordinator 702-494-2749 Facility Manager (or Designee) 702-494-2302 Rescue Team Lead (Hoover Dam Fire and Rescue Brigade Captain) 702-494-2706 Operations 702-494-2231

(Table-1. Program Roles and Contact Information)

MARK COOK 2022.02.09 13:33:59

-08'00'

Exhibit 1

B. ROLES AND RESPONSIBILITIES:

1. Area Office Manager (AOM):

a. Provides necessary resources to implement and maintain the procedures in the

HDCSP. They will also select a program coordinator to implement and maintain the HDCSP. The AOM has designated the LCDO OSHE Manager as the Program Coordinator.

2. Program Coordinator (PC):

a. Responsible for implementing and maintaining this program and has authority to make decisions to ensure the success of this program. In addition, the PC, or a qualified representative directed by the PC, will:

i. Coordinate with the Lower Colorado Basin Industrial Hygienist prior to purchasing equipment for atmospheric testing of PRCS

ii. Conduct/coordinate surveys to identify, inventory/document, and assess all potential PCRSs. The written inventory must list confined spaces, specify whether they are PRCSs, and document associated or potential hazard(s) which must be eliminated or controlled before entry

iii. Coordinate with facility staff to ensure a danger sign is placed at every entrance to PRCS

iv. Maintain this written confined space entry program to protect the safety and health of all affected employees

v. Perform the initial and periodic evaluation of the hazards associated with each confined space

vi. Inform employees via signs and other means where the confined spaces are located and the hazards, they pose

vii. Determine and review Personal Protective Equipment (PPE) required by all entrants entering the PRCS with ES (as necessary)

viii. Review and update list of PRCS trained employees

ix. Assist in coordinating rescue team training and practice as needed

x. Provide and/or coordinate training for air monitoring of PRCS

xi. Coordinate with facility staff to review the HDCSP and cancelled permits annually to ensure compliance

xii. Review as needed Job Hazard Analyses (JHAs) with first-line supervisors regarding PRCS

xiii. Investigate, with coordination of entry and/or first-line supervisor; any near miss, incidents, or when condition of space is outside scope of the permit

xiv. Provide and/or coordinate training for entry supervisors, attendants, and entrants

xv. Review confined space programs submitted by contractors

3. First-Line Supervisors (FLS):

a. The first-line supervisor shall periodically observe employees entering PRCS to ensure all affected employees are in compliance with the HDCSP. In addition, the FCS will:

i. Ensure employees entering or working around PRCSs, including the rescue team have the required training.

ii. Ensure individuals who have air monitoring responsibilities receive training on air monitoring equipment

iii. Verify PRCS engineering and administrative controls are provided, working properly, and in good repair

iv. Ensure hazard assessment and JHAs reflect potential PRCS hazards and document controls for each

v. Ensure the PC is included in the review of JHAs involving PRCS

vi. Review rescue plans in coordination with the entry supervisor and rescue team

vii. Monitor and retain all canceled PRCS entry permits and provide to the PC upon request

4. Entry Supervisor (ES):

a. The ES is qualified and authorized to approve PRCS entry permits. The ES will be identified on the permit and sign it before any entry begins and is authorized to terminate entry when a prohibited condition arises in the confined space. In addition, the ES will:

i. Assess the PRCS and understand/convey any hazards the entry team may face, including information on the mode, signs or symptoms, and consequences of the exposure

ii. Ensure all entry permits are correctly and thoroughly completed

iii. Ensure JHA reflects site conditions and affected employees have been fully informed of its content

iv. Verify all tests have been completed and documented, test results are within the acceptable entry conditions, and all procedures and equipment are in place, before signing the permit and allowing entry

v. Ensure all team members review the safety data sheets (SDS) to ensure understanding of the chemical reaction when introduced to the space to avoid creating a combustible and/or hazardous condition

vi. Verify information in all sections of the SDS and ensure accessibility to employees and the rescue team

vii. Determine and review PPE required by all entrants entering the PRCS

viii. Ensure there is a rescue team/service which meets the requirements of

National Fire Protection Association (NFPA) 350 and Reclamation Safety and Health Standards (RSHS) sec-14, para 14.8.6 for any PRCS entry and allow work time for training and practice

ix. Verify the capability and availability of rescue team/services and the means of summoning them and operable, prior to authorizing entry into a PRCS

x. Ensure at least one rescue team member have current certifications in first aid and cardiopulmonary resuscitation (CPR)

i. If using the Hoover Dam Fire and Rescue Brigade as the rescue team the Hoover Dam Fire and Rescue Brigade Captain will ensure training is up to date

xi. Authorize entry and oversee entry operations

xii. Ensure measures are in place to remove unauthorized personnel who enter or attempt to enter the PRCS during entry operations

xiii. Terminate entry and cancel the permit when with permitted entry operations have been completed or a prohibited condition arises in or near the PRCS

xiv. Investigate any near miss or incident in a confined space, or when a condition outside the scope of the permit arises, in coordination with the PC

xv. Ensure each rescue plan has provisions for conducting the rescue of individuals within a PRCS for each entry

xvi. Determine that entry operations remain consistent with terms of the entry permit and that acceptable entry conditions are maintained

5. Attendants:

a. Attendants must know the hazards that may be faced during entry, including information on the mode, signs or symptoms, consequences of the exposure, and potential behavioral effects on entrants. In addition, the attendant will:

i. Keep an accurate count of how many entrants are in a PRCS at any given time and ensure an accurate means of identifying a specific entrant who is in the space

ii. Remain outside the PRCS when operations are under way until relieved by another attendant

iii. Enter the space for rescue only if trained and equipped for rescue operations and if relieved by another attendant

iv. Communicate with entrant(s) as necessary

v. Monitor activities inside and outside the PRCS to determine if it is becoming dangerous, and order the entrant(s) to evacuate if:

i. A prohibited condition is detected

ii. The entrant shows behavioral effects of hazard exposure

iii. A situation outside the space could endanger the entrant(s)

iv. The attendant cannot safely perform all his or her duties

i. Summon rescue and emergency services if the entrant needs help to escape the confined space

ii. Take the following steps when unauthorized persons attempt to enter the confined space:

i. Warn such persons away from the area

ii. Advise the unauthorized person(s) to exit the space if they have entered it; or

iii. Inform authorized entrants and the entry supervisor that an unauthorized person has entered the space

i. Perform non-entry rescues as specified under the rescue procedures (see the

Rescue Services section)

ii. Perform no other activities that might interfere with the primary duty of monitoring and protecting authorized entrants.

6. Entrants:

a. The entrant shall know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure. In addition, the entrant will:

i. Properly use testing, monitoring, ventilating, communications, lighting, and personal protective equipment, barriers and shields, ladders, and any other equipment necessary for safe entry and exit

ii. Use appropriate PPE per JHA and entry permit

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

b. Leave the PRCS as quickly as possible whenever:

i. An order to evacuate is given by the attendant or the entry supervisor

ii. The entrant recognizes any warning sign or symptom of exposure to a dangerous situation

iii. The entrant detects a prohibited condition

iv. Communication is lost

v. An evacuation alarm is activated

vi. The attendant can no longer perform his or her duties due to injury, illness, or other emergency

vii. A condition outside the confined space exists that could endanger the entrant

7. Project Managers/Contracting Officers Representative (COR):

a. The COR shall ensure any contractors/sub-contractor hired to enter a PRCS provide evidence of current training for all individuals involved in the work. The COR will also ensure each contractor/subcontractor hired to enter a confined space is:

i. Informed the workplace contains PRCS and entry is only allowed through compliance with the HDCSP

ii. Trained to enter the space

iii. Aware of all hazards associated with the space

iv. Provided with all the precautions and procedures to be followed when in or near a confined space

v. Coordinating entry operations with the contractor, when both host employer personnel and contractor personnel will be working in or near PRCSs

vi. Confirm the contractor provides equipment, PPE, and tools necessary to complete PRCS work

vii. Ensure the contractor provides rescue services and prior to starting work, the contractor practices rescue by means of simulated rescue operations from the actual PRCS or representative PRCS for developing a rescue plan

viii. Notify the PC of all contractor PRCS entries before work starts

ix. Debrief contractors at the conclusion of entry operations concerning the

HDCSP and any hazards confronted or created during entry operations and safety procedures taken

b. Additionally, each contractor/sub-contractor performing PRCS entry will:

i. Obtain any available information regarding PRCS hazards and entry operations from the COR

ii. Coordinate entry operations with the COR when Hoover employees and contractor personnel jointly work in or near PRCSs

iii. Inform contractor of the HDCSP and the requirement for compliance

iv. Inform the COR of any hazards confronted or created in PRCS by the work task, either through a debriefing or during the entry operation

8. Rescue Team Members:

a. The rescue team members will be trained to respond to rescue calls by any person recognizing a need for rescue from a confined space. Rescue team members that are employees of Hoover will have current certification in first aid and CPR, have received the same training as authorized space entrants, and have completed training in a simulation of the confined space or a similar confined space before the issuance of the confined space permit. In addition, the rescue members will:

i. Practice PRCS rescues prior to entry and at least once every 12-months, by means of simulated rescue of dummies, manikins, or persons from actual PRCSs or from representative PRCSs

ii. Develop a rescue plan and review with everyone involved in the PRCS entry

iii. Respond immediately to rescue calls from the attendant or any person recognizing a need for rescue from the PRCS

iv. Receive emergency response and all training required of authorized entrants to PRCSs

v. Maintain current certification in first aid and CPR

vi. Evaluate the ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified

vii. Evaluate proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the PRCS identified

viii. Select a rescue team or service from those evaluated that are equipped for and proficient in performing the needed rescue services

ix. Inform each rescue team or service of the hazards they may confront when called on to perform rescue at the PRCS identified

x. Provide the rescue team or service selected with access to all PRCSs from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations

C. TRAINING

1. General Training:

a. The LCDO OSHE office will provide or coordinate training so that employees acquire the understanding, knowledge, and skills necessary for the safe performance of the duties assigned while working in or near confined spaces. Training will be provided to all employees whose work is regulated by the HDCSP:

i. Before the employee is first assigned confined space duties

ii. Before there is a change in assigned duties

iii. Whenever there is a change in PRCS operation that presents a hazard about which an employee has not previously been trained

iv. Whenever the ES and/or PC have reason to believe there are deviations from the confined space procedures or inadequacies in the employee’s knowledge or use of the procedures

b. Note: The training will establish employee proficiency in their duties and introduce new or revised procedures, as necessary, to comply with applicable confined space rules.

c. Specific training program elements:

i. Entrants

ii. Attendants

iii. ES

iv. Rescue teams

d. Note: Training will cover the duties for each type of authorized confined space worker. See the Roles and Responsibilities section for the specific duties.

2. Contractor Training:

a. Contractors, sub-contractors, and employees of contractors must have received the same level of training appropriate to their duties. No contractors will be allowed to enter or work near confined spaces without evidence of the required training.

3. Rescue Team Training:

a. In addition to the specific duties, rescue team members will be trained to:

i. Understand the rescue plan and procedures for each type of confined space at the facility

ii. Learn the access ways and configurations of confined spaces to minimize response time

iii. Perform assigned rescue duties

iv. All members will be certified and current in first aid and CPR

4. Refresher Training:

a. Refresher training shall be conducted as needed to maintain employee competence in entry procedures and precautions. Retraining is required before an employee can be assigned additional confined space duties or if any of the following conditions exist:

i. The employee fails to perform already assigned duties in accordance with the program

ii. The employee has not performed any confined space work for a period of one year

iii. Changes are made in the PRCS program

iv. The employee or first-line supervisor requests retraining

v. The employee was involved in a near miss or incident related to PRCS work

5. Trainee Certification:

a. The PC and/or ES will certify that the training required has been accomplished and that the employee is proficient in his or her authorized duties. The certification will contain each employee’s name, the signatures or initials of the trainers, and the dates of training. It will be available for inspection by employees and their authorized representatives. A copy of the applicable training roster would contain this information.

b. Training Program Assessment. Assessments of the effectiveness of employee training will be periodically conducted by the PC. Copies of the assessments will be maintained for a period of 1-year.

6. Recordkeeping:

a. All requisite training records will be kept by the LCDO OSHE office.

b. Each confined space at the facility will be evaluated to determine its classification as a PRCS. No one may enter any confined space until it has been evaluated.

D. SURVEY AND LIST OF CONFINED SPACES

1. Survey:

a. The PC will ensure that a survey of the facility is conducted to identify all types of confined spaces. The survey will be updated whenever a new confined space is created, or conditions change in existing spaces. This information can be found on the

LCDO shared drive under “Safety Public Folder/Confined Space”. Additionally, this will be addressed during the annual CSP Review.

2. Pre-Entry Certification:

a. The ES will verify that pre-entry measures have been followed through a written certification that contains the date, the location of the space, and the signature of the person providing the certification. The certification will be made before entry and will be made available to each employee entering the space or to that employee’s authorized representative. This information should be maintained on the JHA.

3. Equipment:

a. Entrants, attendants, and any other support personnel will be provided with all equipment necessary to work in a confined space safely. The following is a list of the type of equipment that will be provided as needed:

i. Testing and monitoring equipment

ii. Ventilating equipment needed to obtain acceptable entry conditions

iii. Communications equipment

iv. Personal protective equipment if feasible engineering and work practice controls do not adequately protect employees

v. Lighting equipment needed to enable employees to see well enough to work safely and to exit the space quickly in an emergency

b. Intrinsically safe lighting and equipment will be used in potentially explosive or combustible spaces.

i. Barriers and shields as required

ii. Equipment, such as ladders, needed for safe entry and exit by authorized entrants

iii. Rescue and emergency equipment, except to the extent that the equipment is provided by rescue services

E. PERMIT SYSTEM

1. Before entry is authorized, the ES will prepare an entry permit that describes the means, procedures, and practices necessary for safe entry, including:

a. Specifying acceptable entry conditions, including recording of gas detector readings

b. Isolating the PRCS

c. Purging, flushing, or ventilating the PRCS to eliminate or control atmospheric hazards

d. Providing barriers as necessary to protect entrants from external hazards

e. Verifying that conditions in the PRCS are acceptable for entry throughout the duration of an authorized entry

f. Note: The permits (and all other attachment documents) are located near the 4-gas meter table outside the OSHE office, on the 6th floor

2. Note: Before entry, the ES will sign the permit to authorize entry. The completed permit will be made available to all authorized entrants to confirm that pre-entry preparations have been completed. The duration of the permit will not exceed the time required to complete the assigned task or job.

3. The ES will terminate entry and cancel the permit when:

a. Operations have been completed

b. A condition that is not allowed under the entry permit arises in or near the PRCS

4. Note: The ES and PC retains each canceled entry permit for at least 1-year to facilitate the review of the HDCSP. Any problems encountered during an entry operation will be noted on the permit so that appropriate revisions to the plan can be made. Canceled permits will be turned into the safety office for filing.

5. Entry Permit:

a. No one may enter a PRCS except authorized entrants working under a valid permit.

The entry permit that authorizes entry into a PRCS will contain the following items:

i. A description of the space to be entered

ii. The purpose of the entry

iii. The date and authorized duration of the entry

iv. The authorized entrants

v. The personnel serving as attendants

vi. The individual serving as the ES

vii. The hazards of the PRCS to be entered

viii. The measures used to isolate the space and eliminate or control hazards before entry

ix. Measures can include the lockout or tagging of equipment (Hazardous Energy Control Program)

x. The acceptable entry conditions

xi. The results of initial and periodic tests performed, including the names or initials of the testers and indicate when the tests were performed

6. Evaluate PRCS conditions as follows when entry operations are conducted:

a. Test conditions in the PRCS to determine if acceptable entry conditions exist before entry is authorized to begin, except that if isolation of the space is infeasible because the space is larger or is part of a continuous system (such as sewer), pre-entry testing will be performed to the extent feasible before entry is authorized and, if entry is authorized, entry conditions will be continuously monitored in the areas where authorized entrants are working

b. Test or monitor the PRCS as necessary to determine if acceptable entry conditions are being maintained during the course of entry operations

c. When testing for atmospheric hazards, test first for oxygen, then for combustible gases and vapors, then for toxic gases and vapors

d. The rescue and emergency services that can be called and how to call them

e. The communication procedures used by entrants and attendants to maintain contact with each other

f. Equipment, such as testing equipment, to be provided for compliance with the confined space regulation

g. Any other information necessary to ensure employee safety

h. Any additional permits, such as hot work permits, issued for work in the space

7. Issuance of New Entry Permits:

a. If a previously permitted space must have a new permit issued, atmospheric testing must be conducted, and the results must be within acceptable limits. The entry supervisor must verify all precautions and measures called for on the previous permit are still in effect.

8. Permit Posting:

a. The completed permit shall be made available at the time of entry to all authorized entrants or their authorized representatives, by posting it at the entry portal or by any other equally effective means, so that the entrants can confirm that pre-entry preparations have been completed.

9. Permit duration:

a. The duration of the permit will not exceed the time required to complete the assigned task or job identified on the permit. If a space is secured/out of service, the permit may be open indefinitely until the job task is completed. If conditions of the space and/or work change, employees must exit so it can be reevaluated.

10. Permit Cancellation:

a. The ES will cancel entry permits when work in the PRCS is completed or a condition that is not allowed under the permit arises in or near the PRCS. New conditions will be noted on the canceled permit and used in revising the HDCSP. The ES will give the cancelled permit to their FLS (unless ES is FLS). The FLS will keep all canceled entry permits for at least 1-year.

11. Recordkeeping:

a. Cancelled permits shall be retained for one year. Cancelled permits shall not be dispositioned until after review by the PC or qualified designated representative.

F. CONFINED SPACE GENERAL ENTRY REQUIREMENTS

1. Entry:

a. Entry without a permit must be performed in accordance with the general requirements for NPRCS entry and the following specific requirements:

b. Any condition making it unsafe to remove an entrance cover will be eliminated before the cover is removed

c. Before covers are removed, the entrance will be promptly guarded by a barrier that will prevent an accidental fall through the opening and will protect employees in the space from foreign objects entering the space

d. If it is necessary to enter a confined space to collect initial monitoring data or inspect for hazards, the full provisions for entering a PRCS must be implemented

e. Before an employee enters the space, the internal atmosphere will be tested for the following conditions, in the order given, with a calibrated direct-reading instrument:

i. Oxygen content

ii. Flammable gases and vapors

iii. Potential toxic air contaminants

iv. Any other contaminants with the potential to create an Immediate Danger to

Life and Health (IDLH) atmosphere

f. There must be no hazardous atmosphere within the space whenever any employee is inside the space

g. If continuous forced air ventilation will be used, the following will apply:

i. An employee may not enter the space until forced air ventilation has eliminated a hazardous atmosphere

ii. Forced air ventilation will be directed to ventilate the immediate areas where an employee is or will be and will continue until all employees have left the space. The air supply for the ventilation will be clean and may not increase the hazard

iii. The atmosphere within the space will be continuously tested as necessary to ensure that the continuous forced air ventilation is preventing the accumulation of a hazardous atmosphere

h. If a hazardous atmosphere is detected during entry:

i. Each of the employees will leave the space immediately

ii. The space will be evaluated to determine how the hazardous atmosphere developed

iii. Measures will be implemented to protect employees from the hazardous atmosphere before a subsequent entry

i. Before each entry, the ES will verify that the space is safe for entry and that the measures above have been taken, with a written certification giving the date, location of the space, and signature of the person providing the certification

PRCS. The following measures will be implemented by the ES (or Attendant if designated) to ensure the safety of entrants and to prevent unauthorized entry into a confined space:

Identify and evaluate the hazards of the PRCSs before employees enter them by performing atmospheric testing

Post danger signs outside of confined spaces such as “DANGER-PERMIT-REQUIRED CONFINED SPACE-AUTHORIZED ENTRANTS ONLY” or an equally effective means will be used

Designate the persons who are to have active roles in entry operations, their duties, and provide each with the training required by this program

Summon rescue and emergency services for rescuing entrants and for preventing unauthorized personnel from attempting rescue

Coordinate entry operations when employees of more than one employer (i.e., contractor/sub-contractor) are entering a PRCS so that they do not endanger each other

Prepare, issue, use, and cancel entry permits Develop and implement procedures necessary for concluding the entry after entry operations have been completed There will be at least one attendant outside the PRCS for the duration of entry operations When a single attendant monitors multiple spaces, enable the attendant to respond to an emergency in one or more spaces without distraction from the attendant’s responsibilities

Atmospheric Testing. Atmospheric testing is required prior to entry into a PRCS. It is required for two distinct purposes, evaluation of the hazards of the PRCS and verification of acceptable entry conditions of the space exist.

Evaluation Testing. Evaluation and interpretation of test data, and development of the entry procedure, should be done by, or reviewed by, a technically qualified professional (i.e., OSHA consultation service, certified industrial hygienist, registered safety engineer, certified safety professional, etc.) based on evaluation of all serious hazards.

Verification Testing. The atmosphere of a PRCS which may contain a hazardous atmosphere should be tested for residues of all contaminants identified by evaluation testing using permit specified equipment to determine that residual concentrations at the time of testing and entry are within the range of acceptable entry conditions. Results of testing (i.e., actual concentration, etc.)

should be recorded on the permit in the space provided adjacent to the stipulated acceptable entry condition.

Duration of Testing. Measurement of values for each atmospheric parameter should be made for at least the minimum response time of the test instrument specified by the manufacturer.

Testing Stratified Atmospheres. When monitoring for entries involving a descent into atmospheres that may be stratified, the atmospheric envelope should be tested a distance of approximately 4-feet (1.22 m) in the direction of travel and to each side. If a sampling probe is used, the entrant's rate of progress should be slowed to accommodate the sampling speed and detector response.

Initial Air Sampling. Initial air sampling must be conducted at the entrance, at various levels within the space (top, middle, bottom, and around conduits, pipes, and cables), and in various areas of the space (corners and center) to determine the oxygen level and detect the presence of combustibles and toxins. A remote probe is acceptable, and intrinsically safe equipment must be used if a flammable atmosphere is suspected or present. The internal atmosphere shall be tested with a calibrated, direct-reading instrument.

Order of Testing. A test for oxygen is performed first because most combustible gas meters are oxygen dependent and will not provide reliable readings in an oxygen deficient atmosphere.

Combustible gases are tested for next because the threat of fire or explosion is both more immediate and more life threatening, in most cases, than exposure to toxic gases and vapors. If tests for toxic gases and vapors are necessary, they are performed last.

Note: Hoover utilizes a 4-gas metering device which performs the order of testing for the user

Air Monitoring. Air monitoring shall be conducted for the duration of entry. Periodic results shall be documented on the entry permit according to the timeframe established in the JHA. All air monitoring equipment must be calibrated and maintained according to manufacturer’s specifications.

Acceptable Limits. The entry supervisor must evaluate test data for hazardous atmospheres in the PRCS and verify acceptable conditions for entry exist. The atmosphere is considered within acceptable limits when the conditions of Table-2 are maintained. Any space with an atmospheric condition recognized as IDLH is not acceptable for entry.

Hazard Acceptable Condition Oxygen Pre-entry or Working: 19.5% - 23.5% Combustible gas <10% of the lower explosive limit Toxic gases and vapor substances <OSHA permissible exposure limit Carbon monoxide (CO) Pre-entry: </= 12ppm Working limit: </= 50% of PEL (25 ppm) Hydrogen sulfide (H2S) Pre-entry: </= 5 ppm Working limit: </= 50% of PEL (10 ppm) Airborne combustible dust Industry Practice (see OSHA Annotated Table Z-1 for regulatory limits)

(Table-2. Acceptable Conditions of Hazards)

Alternative Entry. Alternate entry procedures may be used for entering a PRCS under the following conditions:

Hazards. The ES, in coordination with the PC, can demonstrate the only hazard is an actual or potential hazardous atmosphere

Controls. The ES, in coordination with the PC, can demonstrate continuous forced air ventilation alone is enough to maintain the PRCS is safe for entry

Monitoring Data. Monitoring data must support the above demonstrations and made available to each entrant

If an initial entry is necessary to obtain this data, the entry shall be performed in compliance with a PRCS permit

Reclassification of a PRCS. A space classified as a PRCS may be reclassified as a NPRCS if:

The PRCS poses no actual or potential atmospheric hazards and if all hazards are eliminated without entering the space

Testing and inspection demonstrate that the hazards have been eliminated The ES has documented that the basis for determining that all hazards have been eliminated through a certification that contains the date, location of the space, and the signature of the person making the determination. See Attachment-1 (Reclassification of Confined Space) for a copy of the reclassification certification form

Note: If it is necessary to enter the PRCS to eliminate hazards, such entry will be performed under the PRCS requirements of this program.

NPRCS. Employees entering a NPRCS need not comply with the permit requirements for confined spaces or duties of authorized personnel provided that:

It has been determined that the forced air ventilation alone (if required) is sufficient to maintain safe entry

The monitoring and inspection data required by the HDCSP are being used Test data collection that requires an initial entry must be performed in compliance with the

PRCS and ES requirements

The determinations and data required are documented and available to employees who enter the space.

New hazards. When hazards arise within a PRCS that has been declassified to a NPRCS, anyone in the space must exit. The ES and/or PC will reevaluate the space and determine if it will be reclassified as a PRCS.

Provisions for Rescue. All PRCS entry permits must include a plan for rescuing the entrants. The rescue plan must meet the tiered rescue modes and times set by NFPA 350 and shown in Table-3.

Rescue teams will be a designated group of employees or a contracted commercial/ municipal service.

Rescue Response Modes. The degree and rapidity of response must consider both anticipated hazards of the space and technical aspects of moving an ill or injured entrant to a stable environment.

Rescue capabilities shall be evaluated by the PC and ES to ensure they are appropriate for the potential complexity and response. If an entrant becomes incapacitated and requires extraction, the rescue team must be capable of response and entry within the times listed in Table-3, Rescue Times by Response Mode.

Consideration should be given to three basic modes of rescue response:

Tier 1: Those that have no recognized hazards but could require technical rescue for extraction should a worker become incapacitated

Tier 2: Those with non-life-threatening hazards requiring rapid intervention Tier 3: Those with life-threatening hazards requiring immediate attention

Response Mode Response Time to Site Time for Rescue Setup and Entry Tier 1 5 minutes 15 minutes Tier 2 On-site 12 - 15 minutes Tier 3 On-site 2 minutes

(Table-3. Rescue Times by Responsible Mode)

Entrant Retrieval System. For non-entry rescue, retrieval systems or methods will be used whenever an authorized entrant enters a PRCS, unless the system increases the overall risk of entry or would not contribute to the rescue of the entrant. If a retrieval system is used, it shall meet the following requirements:

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

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 PRCS more than 5-feet (1.52 m) deep

Attendant Responsibilities. Attendants may attempt a non-entry rescue using the retrieval system to remove an entrant from the confined space only if all the following conditions apply:

The entrant is unable to self-rescue

A life-threatening danger to the entrant is imminent The attendant remains outside the confined space at all times The entrant is attached to the retrieval system The attendant can visually or verbally confirm from outside the confined space that the retrieval system is disentangled from objects in the confined space and free of other obstructions

Medical Treatment for Chemical Exposure. If an injured entrant is exposed to a substance for which a safety data sheet (SDS) is required to be kept near PRCS or the worksite. The printed (electronic versions are not permissible) SDS will be made available to the first responder providing transport and/or the medical facility treating the exposed entrant.

Program Review and Update. The HDCSP will be reviewed annually and updated when:

Changing conditions cause the current program to lose its maximum protection A review of confined space permits (using cancelled permits retained within 1 year after each entry) indicates revision is necessary

Note: Copies of the HDCSP are available for review on the LCDO intranet and at the LCDO OSHE office.

Definitions

Attendant--an individual stationed outside one or more permit-required confined spaces who monitors the authorized entrants and who performs all attendant’s duties assigned in the employer’s PRCS program.

Authorized entrant--an employee who is authorized by the employer to enter a permit-required confined space.

Confined space--a space that:

Is large enough and configured so that an employee can bodily enter and perform assigned work

Has limited or restricted means for entry or exit (i.e., tanks, vessels, vaults, and applicable work pits are spaces that may have limited means of entry.)

Is not designed for continuous employee occupancy

Entry--the action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space.

Entry permit--the written or printed document that is provided by the employer that allows and controls entry into a PRCS

Entry supervisor--the person responsible for determining if acceptable entry conditions are present at a PRCS where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required by this section.

Hazardous atmosphere--an atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a PRCS), injury, or acute illness from one or more of the following causes:

Flammable gas, vapor, or mist more than 10-percent of its lower flammable limit (LFL) Airborne combustible dust at a concentration that meets or exceeds its LFL

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, that would cause irreversible adverse health effects, or that would interfere with an individual’s ability to escape unaided from a PRCS.

Non-permit confined space (NPRCS)--a confined space neither contains nor, with respect to atmospheric hazards, has the potential to contain any hazard capable of causing death or serious physical harm.

Permit-required confined space (PRCS)--a confined space that has one or more of the following characteristics:

Contains or has a potential to contain a hazardous atmosphere Contains a material that has the potential for engulfing an entrant Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section

Contains any other recognized serious safety or health hazard

If you have any questions, please contact Richard Nixon, Safety and Occupational Health Manager at (702)494 2749 or rnixon@usbr.gov. For the hearing and impair, please call the Federal Relay System at (800) 877 8339 (TTY).