Final Confined Space Program Document.pdf

U.S. DEPARTMENT OF STATE

CONFINED SPACE PROGRAM

PROCEDURES

Office of Safety/Health and Environmental Management

(SHEM)

OBO/OM/SHEM

December 2002

Confined Space Management Program Procedures

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Table of Contents

1.0 Introduction and Overview

2.0 Scope

3.0 Policy

4.0 Program Administration - Post

5.0 How to Use the Confined Space Program Document

6.0 Identifying Confined Spaces at Post and Associated Work Tasks

6.1 What is a Confined Space?

6.2 Work Tasks Performed in Confined Spaces

6.3 Non-Entry Work Task Methods

6.4 Determining if the Confined Space is a PACS or PERMISHEM

6.4.1 PACS

6.4.2 PERMISHEM

7.0 Hazard Assessments

8.0 Demarcating Confined Spaces

9.0 Maintaining a Confined Space and Work Task Inventory List

10.0 Annual Review of Confined Space and Work Task Inventory List

11.0 Recordkeeping

Appendices Appendix 1 Required Ventilation Practices for Entrances into PACS Appendix 2 Personnel Responsibilities During PERMISHEM Entries Appendix 3 PERMISHEM Safety Plan Appendix 4 Hazard Assessment Appendix 5 Sample Confined Space and Work Task Inventory Format Appendix 6 Posts Responding to 02 ALDAC 132556 as of January 2003 Appendix 7 Disinfecting Water Storage Vessels through Chemical Treatment, Rinsing and Flushing Appendix 8 Water Storage Vessel Reengineering Appendix 9 Sump Pump Outflow Disconnect Appendix 10 References

Immediately contact SHEM in the event of an incident or mishap involving a confined space which results in injury, illness, inadvertent shutdown of a building system or release of hazardous material.

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1.0 INTRODUCTION AND OVERVIEW

A confined space is a work location that is large enough and configured so that an employee can bodily enter and perform assigned work, has limited and/or restricted openings for entry and that is not designed for continuous occupancy. Confined spaces pose unique health and safety hazards due to their contents, configurations and materials that are introduced during work tasks. The two major factors that lead to mishaps and fatal injuries in confined spaces are failure to recognize and control hazards prior to and during entry and inadequate or incorrect emergency response. A confined space management program is important to prevent unnecessary entry into such spaces and to assure that when entry is required that all protective measures are implemented to protect employees and contractors from hazardous conditions that may exist or be introduced during the particular work task.

Water storage vessels (tanks, cisterns, conduits), sewer systems, cooling towers, underground utility vaults, pits, trenches and fuel tanks are the typical types of confined spaces that can be found at most posts. Preventive maintenance, construction and repair activities at many posts result in personnel entering confined spaces on a regular or emergency basis. Preventive measures to eliminate confined space hazards such as, engulfment, entrapment, confinement, electrical and mechanical hazards may be necessary as well as engineering controls or personal protective equipment to protect entrants from toxic gases, oxygen deficient atmospheres and chemical exposures. If personnel never enter these locations then the confined space hazard does not exist at post.

This document is intended to provide posts with the necessary technical information (as well as sources of technical support) to implement and practice an effective confined space management program whose primary focus is to eliminate the need to enter such locations, or if not feasible, to assess and control hazards that may be present prior to and during entry.

2.0 SCOPE

All posts have been required to implement a confined space program for all government owned (GO), long-term leased (LTL) and short-term leased (STL) properties in accordance with 6 FAM 610 and Chapter 10.1 of the Safety/Occupational Health and Environmental Management Resource Guide (hereinafter referred to as Resource Guide).

All contractors (post, OBO, DS, etc.) who may enter confined spaces on post properties are also required to comply with these directives. This document contains procedures and information necessary to implement the confined space standard contained in the Resource Guide and 6 FAM requirements.

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3.0 POLICY

The goals and objectives of the Department’s confined space program are to:

• Avoid confined space entry by exhausting exterior methods to perform the necessary work, retrofitting the confined space or reengineering the task;

• Ensure safe confined space entry when no other non-entry alternatives are feasible; and,

• Ensure regulatory compliance.

4.0 PROGRAM ADMINISTRATION - POST

• Deputy Chief of Mission (DCM) or Deputy Principal Officer (DPO): In accordance with 6 FAM 616, the DCM/DPO has direct responsibility for safety, health and environmental management at post. The DCM/DPO must ensure that post has the appropriate equipment and personnel to enter confined spaces and that post has requested and budgeted sufficient 7902 and other funds to retrofit confined spaces to avoid entry when appropriate. Depending on the extent of post’s program, funds may be required for: hiring qualified contractors; industrial ventilators (positive and negative pressure); air monitoring equipment; rescue equipment; and, personal protective equipment (air supplied and/or filtering respirators, chemical protective gloves and disposable garments, etc.).

• POSHO: The day-to-day safety, health and environmental management (SHEM) program is managed and implemented by the designated Post Occupational Safety and Health Officer (POSHO). POSHO responsibilities include ensuring that the confined space program is operating in accordance with Department policies and procedures contained herein where confined spaces are entered as a last resort. The POSHO working with other post personnel (ex., SHEM committee, GSO and FM) will facilitate the procurement of equipment and performance of projects that will make entries into confined spaces unnecessary whenever feasible. If entries are necessary, the POSHO shall coordinate with OBO/OM/SHEM all approvals and required oversight of any confined space entry performed by post or contractor personnel to determine that all safety, health and environmental hazards have been eliminated or controlled prior to and during entry.

5.0 HOW TO USE THE CONFINED SPACE PROGRAM

DOCUMENT

This document will assist post in implementing a confined space program at all government owned and leased (both long term and short term) properties as required in 6 FAM 610 and the Resource Guide. Emphasis is on devising methods to avoid entering confined spaces and

Office of Safety/Health and Environmental Management 3 only entering a confined space if it is absolutely necessary providing that all safeguards are in place to protect entrants prior to and during the entry.

The following outlines a systematic approach for implementing a confined space program with references to applicable sections in this document:

1. Appoint the POSHO as the post official with overall responsibility for confined space matters (Section 4.0);

2. Identify all confined spaces and work tasks that may involve entry into these spaces (Sections 6.1 and 6.2);

3. Determine if exterior methods, engineering controls or retrofits can be implemented to eliminate the need for personnel to enter the confined space to accomplish a task (Sections 6.2 and 6.3);

4. Classify the confined spaces requiring entries into Post Approved Confined Spaces (PACS) or Prior to Entry Review Mandatory in SHEM (PERMISHEMs) using the definitions in this program (Section 6.4)

A. For all PACS:

1. Use ventilation equipment according to Appendix 1; and,

2. Ensure that the POSHO approves and oversees all entries;

B. For all PERMISHEMs:

1. Submit a safety plan to OBO/OM/SHEM for SHEM review and comment that contains all the information defined in Appendix 3. This is required even if post is using a contractor or third party to do the work.

2. Await SHEM approval before proceeding with PERMISHEM entries.

3. Assign entry responsibilities in accordance with those listed in Appendix 2 for entrants, attendants, entry supervisors and rescuers.

4. Ensure that the POSHO approves and oversees all entries.

In all cases where confined spaces contain/contained hazardous material or where hazardous materials will be used/generated, SHEM will provide an onsite Certified Industrial Hygienist (CIH) to monitor safety and health during the entry.

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5. Conduct hazard assessments (Section 7.0 and Appendix 4) of all confined spaces that are not listed in this program as PACS or PERMISHEMs to determine their classification;

6. Demarcate all PACS and PERMISHEMs in a way that describes their hazards and requires those planning entries to notify the POSHO to obtain approval prior to entry and arrange for oversight during an entry (Section 8.0);

7. Review the confined space inventory list on an annual basis or update as new properties with confined spaces are added to post’s real estate holdings (Sections 9.0 and 10 and Appendices 4 and 5).

8. Incorporate the A/OPE Accident Prevention Clause (Department of State Acquisitions Regulations (DOSAR), Part 652 – Solicitation Provisions and Contract Clauses) into all contracts for work that may involve PACS and PERMISHEM entries (Section 4.0).

The DOSAR Part 652 is available on the A/OPE Intranet site at http://aope.a.state.gov/dosar52.htm section 652.236-70.

6.0 IDENTIFYING CONFINED SPACES AT POST AND

ASSOCIATED WORK TASKS

6.1 What is a Confined Space?

To determine if a location is a confined space all the following questions about the space must be answered in the affirmative (i.e., yes):

Safe entry into PERMISHEM confined spaces presents many technically complex issues and may exceed the capabilities of some posts. It is suggested that posts implement the following prioritized strategy as a first step in addressing these requirements:

1. Determine whether entry can be avoided entirely or the frequency of entry reduced;

2. Reengineer the maintenance/repair procedure to eliminate the need to enter the confined space;

3. Eliminate the confined space through reengineering; and/or,

4. Identify a local qualified contractor who is fully qualified and experienced to do confined space entry safely.

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• Is the space configured so that it can be bodily entered and is large enough for work to be performed inside of it?

• Does the space have limited or restricted means for entry or exit? and,

• Is the space designed in way that continuous human occupancy is not possible.

Note that the definition does not consider the potential hazards that are posed in the space nor the tasks that will be performed. These aspects become important in determining if an entry can be avoided and whether the confined space is classified as a PACS or a

PERMISHEM.

6.2 Work Tasks Performed in Confined Spaces

Many tasks that are performed in confined spaces are necessary for the proper operation and maintenance of post properties. The most effective means for controlling confined space hazards is to completely eliminate the need to enter the space through the use of alternative technologies, space retrofits or task reengineering. In order to determine if a confined space entry can be eliminated it is necessary to identify all possible tasks that may be performed. Examples of tasks that may require a confined space entry at post are:

• Applying waterproofing coatings or painting surfaces

• Checking and reading meters, gauges, dials and other indicators

• Cleaning and disinfecting water storage systems

• Connecting to existing sewer, water and fuel systems

• Grease removal from grease traps

• Installing, inspecting, repairing and replacing valves, piping, pumps, motors, floats, etc.

• Installing, splicing, repairing and inspecting electrical, communication and security equipment (ex., Closed circuit TV (CCTVs))

• Maintaining and servicing sump pumps

• Removing sludge and other waste materials

• Repairing water, sewage, fuel or other systems

• Rescuing victims of confined space mishaps

• Retrieving objects

• Turning valves

• Unclogging drains and sewers

• Welding, cutting, brazing or abrasive blasting

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6.3 Non-Entry Work Task Methods

Methods to avoid entry into confined spaces include:

• Attaching portable extension rods to tools in order to reach valves that are located in a confined space.

• Developing decision algorithms to assess why and when tasks are being performed.

Some questions that can be asked for water storage vessel cleaning tasks are:

• If post uses distillers for drinking water is it necessary to clean water storage devices as often as is currently being done?

• What are the parameters that determine when water storage devices need to be cleaned and has post measured or assessed these factors before implementing a cleaning schedule?

• Disinfecting water storage systems through rinsing and flushing (see Appendix 7).

• Dislodging blockages in water and sewer systems and pipes with high pressure or power washer water equipment.

• Eliminating tree root impingement on underground systems through gardening, vegetation and root management strategies.

• Employing CCTV or remote videotaping technologies for inspection tasks.

• Installing prefilters on water and fuel systems to remove silt and other particulates before they enter the storage vessel (testing the incoming water or fuel may be necessary to determine the required filter pore sizes).

• Posting signage and issuing periodic admin notices to inform occupants (both office and residential) of items prohibited from being placed in wastewater (ex., grease, food scraps, garden waste) and sewage systems (ex., paper towels, feminine hygiene products, cotton) to minimize the frequency of blockages.

• Removing silt, sludge and other debris using industrial vacuum systems.

• Replacing metal parts with non-metallic or corrosion protected parts to minimize conditions susceptible to early parts failure in facility systems.

• Retrofitting the confined space with more and/or larger access covers (see Appendix 8 for an example of a water storage vessel that was modified at a post resulting in the declassification of the cistern as a confined space).

• Retrofitting sump pumps or other submerged equipment so that they can be brought to the surface for maintenance (ex., rail systems, outflow pipes with disconnects (see Appendix 9)).

• Using pigs, snakes and other remote plumbing devices to unclog drains and sewers.

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6.4 Determining if the Confined Space is a PACS or PERMISHEM

For each space identified as a confined space post must determine if the space is a PACS or PERMISHEM. This determination is based on several factors that consider the purpose of the confined space, the type of hazards posed by the space, the level of safety precautions that must be taken to enter the space and the work task performed.

OBO/OM/SHEM has created a list of PACS and PERMISHEMs based on hazard assessments done at posts. These are described in the following text. If the space is not listed below then post must perform a hazard assessment (see Appendix 4) or contact OBO/OM/SHEM for assistance.

6.4.1 PACS

A PACS is a space where prior SHEM approval for entry is not necessary as long as all of the following criteria are met:

• Positive pressure forced air dilution ventilation will be provided in the space at pre-entry and during entry according to Appendix 1.

• Oxygen deficiency is the only potential atmospheric hazard. It will be controlled by pre- and during entry positive pressure forced air dilution ventilation in accordance with Appendix 1. Following the ventilation procedure will eliminate the need to conduct air monitoring for oxygen levels.

• The contents of the space are non-hazardous and once removed from the space there is no health or safety hazard from any residual.

• The tasks that will be performed inside the space will not involve the use of or generation of hazardous exposures or conditions.

• Air monitoring for oxygen or other toxic and flammable gases is not needed prior to and during entry.

• No respiratory protection is needed to control for exposure. Respiratory protection may be worn for nuisance or comfort reasons only.

• Safety hazards may be present but are controllable through lockout/tagout or other means, such as, blanking, blocking, chocking, or disconnecting. For example, in water storage tanks this would include lockout/tagout of pumps and valving off, blanking off or disconnecting supply pipes.

Examples of possible PACS at post are:

• Bollard, Delta barrier or other security related equipment pits

• Cooling towers

• Crawl spaces

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• Drainage pits

• Electrical and communication vaults, manholes and pits

• Elevator pits

• Fuel tank valve manholes or vaults where no fuel spills or leaks are present

• Storm sewers where the only flow through the system is water and there is no possibility of chemical dumping by others who are connected to the system. The atmosphere in storm sewers may suddenly and unpredictably become lethally hazardous (toxic, flammable or explosive) from causes beyond the control of the post because complete isolation in a sewer system is not possible.

• Water storage vessels (stationary) – Cleaning water storage vessels under the PACS category requires that accumulated sediment/sludge is removed from the bottom of the vessel by manual means and that walls are scrubbed with a wire brush and fresh water to remove all resulting residue. The use of cleaning materials containing chlorine such as bleach solution or any other hazardous material is prohibited due to the significant exposure risks posed to workers.

• Water tank trucks – See cleaning requirement under water storage vessels (stationary)

NOTE: A PACS will become a PERMISHEM when activities are performed in the PACS that create hazardous atmospheres.

6.4.2 PERMISHEM

A PERMISHEM is a space where any one or more of the following criteria apply:

• Potential health hazards are posed from existing or potential internal contaminants or chemicals/gases introduced during tasks performed in the space, or,

• Air monitoring is required prior to and during entry to assure that entrants will not be overexposed to hazardous concentrations of chemicals/gases/particulates, or,

• Respiratory protection is needed for potential exposures that may be present or introduced into the space.

Prior to entry into a PERMISHEM post must obtain OBO/OM/SHEM approval for entry.

Post shall submit a safety plan according to the requirements of Appendix 3 of this program. SHEM will evaluate the safety plan to provide an approval to proceed, require modifications to the plan before the entry is conducted or override the plan and require that the entry be performed by a qualified SHEM contractor. SHEM will also determine if oversight by a SHEM-selected CIH is required during the entry. The safety plan will then serve as the entry permit. If the same PERMISHEM needs to be entered at a later

Office of Safety/Health and Environmental Management 9 date, post must re-submit the PERMISHEM (which can be a copy of the original

PERMISHEM).

The rationale supporting the establishment of the PERMISHEM system is:

• Most posts are not able to obtain and/or maintain specialized safety and health equipment to perform confined space entries in a safe manner.

• Most posts do not have the experience, practice or skill to perform confined space entry safely.

• Most posts are unable for innumerable reasons to manage or implement a confined space program that marginally meets the requirements of 6 FAM 610 and Chapter

10.1 of the Safety/Occupational Health and Environmental Management Resource Guide.

Typical PERMISHEMs at posts are:

• All confined spaces that are not PACS

• Fuel tanks

• Sanitary sewer systems (including ejector stations)

• Sewer manholes

• Storm sewers where there is a possibility that other upstream users may dump chemicals or sewage into the system. The atmosphere in storm sewers may suddenly and unpredictably become lethally hazardous (toxic, flammable or explosive) from causes beyond the control of post because complete isolation in a sewer system is not always possible.

Typical tasks that create a PERMISHEM or that transform a PACS into a PERMISHEM are:

• Applying coatings (water or solvent based)

• Cleaning surfaces with products other than water

• Connecting to existing sewer or fuel systems

• Installing, inspecting, repairing and replacing valves, piping, pumps, motors, etc. in sewage systems

• Removing sludge and other waste materials from waste systems or fuel tanks

• Use of chemicals and gases

• Use of other combustion equipment such as fossil fuel fired motors, engines, heaters and generators

• Welding, cutting, brazing or abrasive blasting

The hazard control actions that need to be implemented for a PERMISHEM entry are:

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• Preventing unauthorized entry into the space

• Identifying and evaluating the hazards before entry

• Developing and implementing the means, procedures and practices necessary for a safe entry

• Providing, maintaining and ensuring that the following equipment is used:

• Air testing and monitoring equipment

• Ventilation systems

• Communications devices

• Personal protective equipment

• Lighting units

• Access equipment for ingress and egress from the space

• Barriers and shields to protect the work area from on-lookers

• Rescue and emergency equipment

In addition to the hazard control actions described above, a PERMISHEM entry requires numerous personnel to be available. These include: authorized entrants; attendants; an entry supervisor which may be the POSHO; the POSHO and, a means to rescue entrants.

The duties of each group are described in Appendix 2.

7.0 HAZARD ASSESSMENTS

If post encounters a confined space or an activity that has not been previously listed in its inventory or defined under the PACS and PERMISHEM categories in this document then a hazard assessment must be performed to determine how the confined space should be classified and what controls are needed to minimize hazards. The hazard assessment is also a useful tool for posts to follow when formulating safety plans for entry into PERMISHEMs. Appendix 4 provides extensive guidance on how to perform a hazard assessment.

8.0 DEMARCATING CONFINED SPACES

The purpose of demarcating confined spaces is to prevent unintentional and unprotected entry into confined spaces. Entry into both categories of confined spaces (PACS and PERMISHEMs) requires that the POSHO approve and oversee entry and that certain controls be instituted prior to and during entry. Posts must inform employees who may possibly enter confined spaces through either the posting of signs on access ways, in English and the local language, as in Figure 1 or any other equally effective means of

Office of Safety/Health and Environmental Management 11 notifying personnel of the location and danger posed by these spaces. If posting signs is not feasible, work orders that involve PACS or PERMISHEMs can be revised to include warning statements, in both English and the local language, alerting personnel to contact the POSHO before entry. Alternatively the inventory of all PACS, PERMISHEMS and work activities that may involve entry into confined spaces can be maintained as long as employees are notified of this list, its contents and its location on a regular basis.

FIGURE 1: SAMPLE NOTIFICATION SIGN

DANGER

CONFINED SPACE

DO NOT ENTER

CONTACT THE POSHO

9.0 MAINTAINING A CONFINED SPACE AND WORK TASK

INVENTORY LIST

Once all confined spaces and work requiring confined space entry have been identified post should prepare an inventory list that can be reviewed annually and updated as properties change. The list should indicate whether the space/task is a PACS or PERMISHEM and other program requirements. Appendix 5 contains a sample inventory sheet.

In July 2002, OBO/OM/SHEM requested that posts submit an inventory of their confined spaces (02 ALDAC 132256) or indicate that there are no confined spaces at post. Over 50% of posts responded. Copies of these inventories (without the PACS or PERMISHEM column) are available from SHEM and are also posted on the SHEM website at http://obo.state.gov/opssaf-shem. Appendix 6 contains a list of posts that responded to the ALDAC as of January 2003. Updates to the list will be available on the Intranet.

10.0 ANNUAL REVIEW OF CONFINED SPACE INVENTORY

To ensure continuity of the confined space program the confined space and work task inventory must be reviewed annually. This review will assist post in maintaining its program through property and personnel changes.

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11.0 RECORDKEEPING

Post must keep the following documents for the duration listed below.

Confined Space and Work Task Inventory Duration of post’s operation

SHEM approved Safety Plans for PERMISHEMs

At least one year, however preferable to keep as long as the PERMISHEM may be entered during post’s operation

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APPENDIX 1: REQUIRED VENTILATION PRACTICES FOR

ENTRIES INTO PACS

This section focuses on ventilation practices for entries into PACS (defined in Section 6.4.1 of this document) where there is no possibility for toxic or flammable atmospheres in the confined space from chemicals or work tasks, such as welding, painting, chemical use, etc.

These types of work situations will require the use of other control measures. Such confined spaces and tasks are PERMISHEMs. For PERMISHEMs, post must submit a safety plan to OBO/OM/SHEM detailing ventilation and other controls prior to entry. The ventilation practices described below may apply in the PERMISHEM but these practices will be supplemented by other controls.

The primary safety and health concerns in entering PACS are lack of oxygen and physical hazards. Oxygen deficiency can result from displacement by other gases but more likely in PACS by biological or chemical reactions (i.e., rusting in steel tanks, decay of accumulated organic matter). Oxygen deficiency can be eliminated through the use of continuous ventilation both before and during the entry. Because each confined space is uniquely designed there is no single ventilation methodology that applies to every situation. There are however generic guidelines that can be followed that will define the ventilation plan.

Hazard Assessment and Pre-planning Information for Ventilation of PACS

Preplanning for proper ventilation before and during the entry requires the gathering and review of various pieces of critical information:

PACS design and configuration

• How many portals can be opened to promote air mixing in the PACS and overcome short-circuiting? The more that can be opened at opposite ends and sides of the PACS the higher the likelihood that short-circuiting will not occur. (See short-circuiting section below).

• What are the dimensions of the PACS? This will determine both the duration of pre-entry ventilation, the size of the fan and the lengths of hose that are needed to ensure air dispersal throughout the vessel.

• Are there any internal obstructions that will adversely affect airflow through the PACS?

If so, additional flexible ducting may be needed to deliver air to dead spaces and pockets by going around the obstruction.

Work task location in the PACS

• Where will the work be performed within the space? Knowing this is critical to ensuring that properly sized ventilation equipment is used with sufficient hose length to distribute air into the space.

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Ventilation Fan Specifications – Industrial fans designed for confined space entry must be used and not fans used in the office environment (see Figure 2 for examples of appropriate fans).

• What is the power source for the ventilator? If combustion type then the exhaust from the engine must be diverted far away from the intake for the fan and occupied spaces so combustion byproducts (CO, hydrocarbons, etc.) don’t get introduced into the confined or occupied spaces. If electric, the power cord must be able to reach an outlet without compromising the position of the fan at the confined space entry portal or the ductwork’s extension into the space.

• How many cubic feet per minute (CFM) of air can be delivered by the blower without any attachments and with attached flexible ductwork? The CFM ratings of the fan are critical to calculating the duration of pre-entry ventilation. It will also impact the amount of air that will pass through a long length of ductwork. If the static pressure drop is high through the ductwork then the CFM will have to increase to provide sufficient air to the work area. This information should be obtained from the fan manufacturer if not already on hand.

• What are the fan dimension? If the space around the PACS is small and the fan is large then this will impact the ease with which the fan is used, where it can be set up and how employees will maneuver around to do their work in a safe manner.

Pre-Entry Ventilation

The duration of pre-entry ventilation varies depending on the type of PACS. The ventilation period can be as short as 10 minutes or as long as 24 hours depending on the PACS to be entered.

24 hour Pre-Entry Ventilation A pre-entry ventilation period of 24 hours is required for PACS that normally operate under sealed conditions or that are not normally exposed to the ambient atmosphere. These include:

• Cooling towers

• Drainage pits

• Fuel tank valve manholes or vaults where no fuel spills or leaks are present

• Storm sewers where the only flow through the system is water and there is no possibility of chemical dumping by others who are connected to the system.

• Water storage vessels (stationary)

• Water tank trucks

Variable Pre-Entry Ventilation The pre-entry ventilation period for PACS where the space is operated with exposure to ambient air varies depending on the fan being used for ventilation and the volume of the space. PACS subject to variable pre-entry ventilation are:

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• Bollard, Delta barrier or other security related equipment pits

• Crawl spaces

• Electrical and communication vaults, manholes and pits

• Elevator pits

The following equation (developed by a major communications company in the U.S. for entry into utility manholes) can be used to determine the pre-entry ventilation time for the particular PACS to be entered:

T = 7.5 V C where, T = ventilation time in minutes

V = estimated volume of the space in cubic feet (ft3) – do not enter the space to calculate, and

C = effective blower capacity in cubic feet per minute (CFM) – effective blower capacity is the actual quantity of air (CFM) delivered at the end of the flexible duct connected to the blower. If no ductwork is connected then this is the quantity of air delivered at the outlet of the blower.

During Entry Ventilation

The ventilator must be left operating and ventilating the PACS during the entire time that someone is inside the space.

Ventilation Challenges

Unfortunately, just placing a fan next to a PACS opening or dropping flexible ducting into the PACS for a specified period of time is not sufficient to assure adequate ventilation.

There are some typical problems that frequently arise in ventilation that need to be overcome during the time that forced air ventilation is provided.

Contaminant Re-entrainment As discussed above, if an internal combustion engine powers the blower, it is absolutely necessary to ensure that exhaust gases are not drawn into the blower’s fresh air intake.

Exhaust gases need to be vented through ductwork or tubing at least 25 feet downwind from the fan intake. The fan intake must also be placed away from other sources of contamination, such as, vehicle exhaust pipes and/or other activities that generate contaminants (painting, welding, operating generators, etc.). If it is not possible to provide a safe distance from these activities then the confined space entry should be planned when these activities will not impact on the pre-entry and during entry ventilation.

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Short-Circuiting Short-circuiting occurs when air that is being introduced into a vessel exits before circulating throughout the vessel. Examples of short-circuiting and ways to overcome it are shown in Figure 3 below.

Portal Obstructions Many confined spaces have only one opening for entry. The ductwork used to ventilate a vessel may have to be placed through the same opening that is used for entry and exit from the space. If the portal is small, the space occupied by the duct will restrict entry and egress even more. A product called a Saddle Vent (see picture below) can be used to change the profile of the ductwork and provide more room to the opening without compromising the airflow.

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FIGURE 2: VENTILATION EQUIPMENT FOR CONFINED SPACES

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FIGURE 2, Continued

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FIGURE 3

OVERCOMING SHORT-CIRCUITING DURING CONFINED SPACE

VENTILATION

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APPENDIX 2: PERSONNEL RESPONSIBILITIES DURING

PERMISHEM ENTRIES

A substantial number of personnel are required to conduct a PERMISHEM confined space entry.

At a minimum each PERMISHEM entry shall involve the services of at least one:

• Authorized entrant

• Authorized Attendant

• Entry supervisor which may be the POSHO

• The POSHO

• Rescue Service which may be the local fire services

The specific responsibilities of these individuals during a confined space entry are:

Authorized Entrants

• Know the hazards of the confined space and signs of symptoms of exposure to atmospheric hazards

• Use appropriate personal protective equipment properly

• Maintain communication with attendants to enable the attendant to monitor the entrant’s status as well as to alert the entrant to evacuate the confined space

• Exit from the confined space as soon as possible when ordered by an attendant or entry supervisor, when a prohibited condition exists, when the entrant recognizes the warning signs or symptoms of exposure or when an alarm is activated

Authorized Attendants:

• Know the hazards of the confined space and signs of symptoms of exposure to atmospheric hazards

• Continuously maintain an accurate count of authorized entrants in the PERMISHEM and ensure that only authorized entrants access the space

• Remain outside the PERMISHEM during entry operations until relieved by another authorized attendant

• Communicate with authorized entrants as necessary to monitor their status and to alert them to situations that may require them to evacuate the PERMISHEM

• Monitor activities inside and outside the space to determine if it is safe for authorized entrants to remain in the space

• Initiate an evacuation under the following conditions:

• If a prohibited condition is detected

• If the authorized entrants display signs and symptoms of exposure to atmospheric hazards

• If a situation outside the PERMISHEM occurs that could endanger the authorized entrants

• If the authorized attendant cannot effectively and safely perform all the requisite duties

• Summon rescue and other emergency services when needed

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Entry Supervisor (may be the POSHO)

• Knows the hazards that may be faced during the PERMISHEM entry

• Verifies, by checking that the appropriate items on the safety plan have been completed, that all tests specified by the safety plan have been conducted and that all procedures and equipment on the safety plan are in place before endorsing the safety plan and allowing entry into the PERMISHEM

• Terminates the entry and cancels the safety plan by signing and recording the time in the END of ENTRY field on the safety plan

• Ensures that a means for rescue is available should a mishap occur in the PERMISHEM and that rescue services are informed of the hazards in the PERMISHEM prior to entry

• Removes individuals who attempt to enter the PERMISHEM who are not authorized entrants

• Ensures that the POSHO has signed off on the safety plan and is available to oversee the entry

POSHO

• Knows the hazards that may be faced during the PERMISHEM entry

• Verifies, by checking that the appropriate items on the safety plan have been completed, that all tests specified by the safety plan have been conducted and that all procedures and equipment on the safety plan are in place before endorsing the safety plan and allowing entry into the PERMISHEM

• Terminates the entry and cancels the safety plan by signing and recording the time in the END of ENTRY field on the safety plan

• Ensures that a means for rescue is available should a mishap occur in the PERMISHEM

• Removes individuals who attempt to enter the PERMISHEM who are not authorized entrants

Office of Safety/Health and Environmental Management 24

APPENDIX 3

PERMISHEM SAFETY PLAN

Posts that enter PERMISHEMs must submit a safety plan to OBO/OM/SHEM prior to the entry for SHEM review and approval. In some cases the level of hazard posed by the entry may be great enough for SHEM to provide on-site oversight during the entry. The safety plan provides the needed information for SHEM to make that determination. Once approved by SHEM it also serves as the confined space entry permit when the POSHO approves and oversees the entry.

When formulating a safety plan for a PERMISHEM post is advised to review Appendices 1 and 4. Information in these sections may be useful for development of the safety plan. The Safety/Occupational Health and Environmental Management Resource Guide (SHEM Resource Guide) should also be consulted during safety plan development. The chapters entitled Hazard Control Ventilation, Respiratory Protection, Personal Protective Equipment, Machinery and Machine Guarding and Electrical may be useful.

The minimum elements of a PERMISHEM safety plan are:

• A description of the space and its contents

• The purpose of the entry

• The work tasks to be performed in the space

• Whether or not non-entry techniques were investigated. If not, why?

• A list of all chemicals and/or gases to be introduced in the space

• The date and authorized duration of the entry

• A description of all the hazards of the space

• Measures that will be taken to isolate the space and manage the hazards

• The acceptable atmospheric entry conditions

• How will air sampling be conducted and how often

• Who will perform air sampling and their qualifications

• What air sampling instrumentation will be used

• What contaminants will be sampled for

• Communications procedures

• Special equipment provided

• The identity of the authorized entrants and attendant

• Identification of other permits that may be needed (ex., hot work)

Office of Safety/Health and Environmental Management 25

• Rescue and emergency equipment/services that can be summoned or provided

• The POSHO and Supervisor’s name

In addition, post must submit a drawing or photos of the confined space with the safety plan to assist with its evaluation. The following form may be used for the safety plan.

PERMISHEM SAFETY PLAN

(Please attach a drawing and/or photos depicting the confined space.)

Post Name __________________________ Date: __________________________ POSHO: __________________________

Use additional sheets of paper if necessary.

Confined Space: Expected Date of Entry: Expected Duration of Entry: hours Address: Purpose for Entry: What non-entry methods were considered?

Chemicals and gases that will be brought into the space.

Tools & equipment that will be brought into the space:

Work tasks to be performed:

Identify hazards associated with entry:

Atmospheric Hazards:

1.

2.

3.

4.

5. Physical Hazards:

1.

2.

3.

Other Hazards:

1.

2.

Describe how each hazard listed will be controlled and note required permits, if any.

Atmospheric Hazard Controls:

1.

2.

3.

4.

5. Physical Hazard Controls:

1.

2.

3.

Other Hazard Controls:

1.

2.

Describe how atmospheric hazards will be monitored prior to and during entry.

Instrument Name:

Gases instrument capable of detecting:

Alarm set points for each gas:

Date of last calibration:

Air sampler’s name and job title:

Describe ventilation procedures

• Pre-entry

• During entry

Personal protective equipment required for entry __ Respirators (type) __________________ __ Head protection __ Ear protection __ Eye protection __ Chemical __ Hand protection protective clothing

Means for accessing the interior of the space

Communication Methods __ Voice __ Rope Signals __ Radio __ Other _____________

Name of all entrants Name of attendants

Emergency response procedures Entry Supervisor’s Name OBO/OM/SHEM approval:

ON DAY OF ENTRY

DATE ____________

POSHO APPROVES ENTRY (time, sign) ENTRY SUPERVISOR APPROVES ENTRY (time sign)

SHEM CIH (if applicable) (sign, time)

END OF ENTRY POSHO TERMINATES ENTRY (time, sign)

ENTRY SUPERVISOR TERMINATES

ENTRY(time, sign)

SHEM CIH (if applicable) (sign, time)

Confined Space Management Program Document

Office of Safety/Health and Environmental Management 27

APPENDIX 4: HAZARD ASSESSMENT

Confined space hazards can be divided into two categories: atmospheric hazards and physical hazards. Oxygen deficiency, oxygen enrichment, flammable and toxic gases and vapors represent the majority of atmospheric hazards. Atmospheric hazards account for the majority of fatalities in confined spaces in the United States. Hazards in confined spaces can be present as a result of the intended purpose of the space and by what may be introduced into it by the entrants through their tools and equipment or types of tasks they will perform.

A confined space hazard assessment must evaluate the potential for atmospheric hazards and physical hazards inside the space and those that are introduced during work tasks. Table 1 lists a series of questions that should be evaluated during the hazard assessment. The following discussion will assist post in conducting a hazard assessment of confined spaces at post that are not already classified as PACS or PERMISHEMs (see Sections 6.4.1 and 6.4.2 of this document). If the results of hazard assessment identify any potential atmospheric hazards that result in the confined space being classified as a PERMISHEM, then a safety plan must be submitted to OBO/OM/SHEM prior to entry.

TABLE 1: HAZARD ASSESSMENT QUESTIONS

Atmospheric Hazards Physical Hazards Other Hazards

• Could the atmosphere be oxygen deficient or oxygen enriched?

• What air contaminants may be present in the space?

• What did the space last contain?

• Could the atmosphere be flammable?

• Does the atmosphere have the potential for becoming flammable?

• Do residues pose any hazards?

• Do adjacent processes or operations present any potential hazards?

• Will air contaminants be introduced into the space by processes such as welding, coating application or cleaning?

• Are there any energized electrical lines?

• Does the space contain any mechanical equipment?

• Will any hazards be posed by portable equipment taken into the space?

• Are interior surfaces potentially slippery?

• Are there any projections or objects that could cause cuts, bumps or abrasions?

• How large is the entry portal and where is it located?

• Do adjacent processes or operations pose any potential hazards?

• Are any fluid lines attached?

• Does the configuration pose any unusual problems?

• Are there any external hazards such as pedestrian and vehicular traffic?

• Will excessive noise be present to impair communications?

• Is there a possibility for being submerged in fluid or other materials?

• Is there any potential for vermin, poisonous animals or pests like wasps, bees, spiders and snakes to be present?

• Is there a potential for exposure to biological hazards, such as, bloodborne pathogens human waste products (ex., fecal matter) that would require implementation of a disinfection or decontamination procedure prior to entry?

Office of Safety/Health and Environmental Management 28

A. ATMOSPHERIC HAZARDS

The only way to assess potential atmospheric hazards is to collect air samples prior to and during entry at the entrance to the confined space and in the work area with a calibrated air sampling instrument. The instrument must be carried throughout the space since levels can stratify by depth or by work location due to air flow patterns unique to the confined space and work tasks taking place. The instrument must be capable of detecting the type of atmospheric hazard that is potentially present. An oxygen meter cannot indicate whether or not a flammable atmosphere exists. Likewise, a carbon monoxide meter cannot assess levels of hydrogen sulfide. Atmospheric hazards commonly associated with typical confined spaces and tasks found at posts are listed in Table 2 below.

TABLE 2: POTENTIAL ATMOSPHERIC HAZARDS ASSOCIATED WITH

COMMON CONFINED SPACES AND TASKS

Confined Space Type or Task Potential Atmospheric Hazards* Water Storage Vessels and Trucks Oxygen deficiency Bollard, Delta barrier or other security related equipment pits

Oxygen deficiency

Crawl spaces Oxygen deficiency Electrical and communication vaults, manholes and pits

Oxygen deficiency

Elevator pits Oxygen deficiency Cooling Towers Oxygen deficiency Storm sewers without flow from other facilities Oxygen deficiency Sewer Systems Oxygen deficiency

Methane (flammable atmosphere) Hydrogen Sulfide (toxic atmosphere)

Fuel Tanks Oxygen deficiency Gasoline/fuel vapors (flammable atmosphere) Benzene and other organic compounds (toxic atmospheres) Applying Coatings Toxic atmospheres (depending on coating being applied) Flammable atmospheres (depending on coating being applied) Welding Metal fume (depending on metal being welded)

Welding gases – flammable atmosphere

• Acetylene

• Oxygen Enrichment

• Hydrogen Welding gases – oxygen deficient atmosphere

• Nitrogen

• Argon

*These are typical atmospheric hazards associated with these types of confined spaces/activities.

Other atmospheric hazards may be present that need to be identified prior to entry due to nearby operations, leaks from natural gas lines, underground systems, etc.

Office of Safety/Health and Environmental Management 29

An air sampling strategy must not only identify and predict the material that needs to be sampled but involve the evaluation of the entire confined space and specific work areas.

Skilled professionals knowledgeable in the operation and maintenance of air sampling instrumentation and the interpretation of results must be available to perform air sampling if it is required for a confined space entry. If air sampling is necessary to assess the level of atmospheric hazard then the confined space is classified as a PERMISHEM per Section

6.4.2 of this document. Posts must submit a safety plan to OBO/OM/SHEM in such cases prior to the entry to ensure that air sampling will be done properly.

A.1 Oxygen Deficiency (< 19.5%)

Definition: Ambient air contains 21% oxygen. An oxygen deficient atmosphere occurs when the measured oxygen level is below 19.5%. As the oxygen level falls below 19.5% the body will begin to display various physiological and behavioral changes until the level is low enough to result in death from asphyxiation. In confined spaces where oxygen deficiency is the only possible atmospheric hazard, positive pressure ventilation with clean air over a sufficient period of time can effectively change an oxygen deficient atmosphere into a safe environment (see Appendix 1).

Oxygen deficiency results from chemical or biological reactions which adsorb, displace, or consume oxygen, such as:

• Combustion of flammable substances, as in welding, cutting, brazing or the use of fossil fuel fired space heaters used for comfort or process heating;

• Bacterial action, as in the fermentation of organic debris such as soil, grass and leaves that may accumulate at the bottom of a manhole or water cistern. This process also has the potential to emit toxic gases such as hydrogen sulfide or oxygen displacing and flammable gases such as methane;

• Slow chemical reactions, as in the formation of rust on exposed surfaces of metal tanks, rebar access ladders in manholes and cast iron valves;

• Adsorption of oxygen onto porous surfaces such as activated carbon which may be found in HVAC systems and waste water treatment facilities;

• Oxygen displacement by biologically inert gases such as argon, carbon dioxide, helium, methane and nitrogen when present in an overabundant amount as to diminish the amount of oxygen in the space. Purging vessels with inert gases, the introduction of inert gases during welding or other work tasks, or leaking nearby gas lines can cause oxygen deficient atmospheres from displacement.

Health Effects: Oxygen deprivation is a form of asphyxiation. When atmospheric oxygen level drops below 17%, the first sign of hypoxia (low blood oxygen level) is a deterioration of night vision, which is usually not noticeable to the potential victim. Other physiological effects include breathing disturbances and accelerated heartbeat. Between 14% and 16% additional physiological effects are poor muscular coordination, rapid fatigue, and

Office of Safety/Health and Environmental Management 30 intermittent respiration. Between 6% and 10%, the effects are nausea, vomiting, inability to perform and unconsciousness. At concentrations less than 6% there is a rapid loss of consciousness and death in minutes. It is important to realize that oxygen levels can drop dramatically in a confined space as an individual progresses through the confined space. The health effects occur instantaneously and without delay.