Confined Space Program Safety Compliance

Policy # Revision # Effective Date Page Number 5102 6 09/01/23 1 of 35

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Table of Contents

1.0 Purpose

2.0 Scope

3.0 Policy Statement

4.0 References

5.0 Definitions

6.0 Roles and Responsibilities

6.1 CVG Safety Department

6.1.1 CVG Safety Department Responsibilities

6.2 CVG Management and Supervision (Including Leads)

6.2.1 CVG Departmental Managers Responsibilities

6.2.2 CVG Planning and Development Department Responsibilities

6.2.3 CVG Construction Inspectors Responsibilities

6.2.4 CVG Project Managers Responsibilities

6.3 Airport Operations Center (AOC) Responsibilities

6.4 Airport Rescue and Firefighting (ARFF) Department Responsibilities

6.4.1 Rescue Service and Emergency Services Responsibilities

6.4.2 Hot Wok Permits

6.5 Controlling Contractor Responsibilities

6.6 Private (Contractor) Confined Space Rescue Teams Responsibilities

6.6.1 OSHA General Industry Operations

6.6.2 OSHA Construction Industry Operations

7.0 General Requirements

7.1 Scope of Activity between OSHA Construction and General Industry

7.2 Confined Space Identification

7.3 Non-Permit Confined Space

7.3.1 Safe Work Procedures (SWP)

7.4 Preventing Unauthorized Entry

7.4.1 Signage

7.4.2 Access Protection

7.4.3 Reporting Unauthorized Entry or Attempts to Entry

7.5 Confined Space Survey

7.6 Confined Space Rescue Pre-Planning

7.7 Evaluation of Confined Space Program

8.0 Permit System

8.1 No Entry

8.2 Confined Space Entry Permit (Refer to Appendix C)

8.2.1 Confined Space Permit Form Information Requirements

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8.3 Entry Supervisor

8.3.1 Entry Supervisor Responsibilities

8.3.2 Assumption of Other Duties/Entry by the Entry Supervisor

8.3.3 Transfer of Duties

8.3.4 Coordination with Non-CVG Employees/Contractors

8.4 Attendant

8.4.1 Responsibilities

8.5 Authorized Entrant

8.6 Pre-Entry Briefing

8.7 Availability and Posting

8.8 Permit Duration

8.9 Canceling the Permit (Refer to Appendix C)

8.10 Suspending the Permit (Refer Appendix C)

8.11 Information Recording

8.12 Retention

8.13 Alternate Procedures and Reclassifying a Confined Space

8.13.1 Reclassification Required Conditions (Refer to Appendix E)

8.13.2 Alternate Entry Procedure - Ventilation Controlled Atmospheric Hazards (Refer to Appendix D)

8.13.3 Posting/Employee Notification

8.13.4 Return to Permit Required Status

8.14 Tracking

9.0 Atmospheric Monitoring (Refer to Appendix G)

9.1 Acceptable Atmospheric Entry Conditions

9.2 Air Monitoring (Atmospheric) Sampling Techniques

9.3 Atmospheric Hazard Control Methods

9.3.1 Ventilation (Refer to Appendix I)

9.4 Inerting

9.5 Respiratory Protection - PPE

9.6 Prohibited Conditions

10.0 Chemical, Physical and Other Hazards

10.1 Hazard Assessment

10.2 Hazardous Materials/Chemical Hazards

10.3 Physical Hazards

10.4 Control Methods

10.4.1 Hazardous Materials/Chemical Hazards

10.4.2 Physical Hazards

10.4.3 Isolation and Lockout/Tagout Procedures for Confined Space Entry

10.4.4 Hot Work (Refer to Appendices F & J)

10.4.5 Personal Protective Equipment (PPE)

10.4.6 Lighting

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10.4.7 Entry and Retrieval Equipment

10.5 Acceptable Entry Conditions

10.6 Prohibited Conditions

11.0 Confined Space Entry with Non-CVG Employees/Contractors

11.1 CVG Controlled Sites

12.0 Communications

12.1 Visual Signaling/Vocal Contact

12.2 Signaling System

12.3 Other Forms of Communication

12.4 Emergency Notification

12.5 Inability to Establish Effective Communication System

12.6 Entry Supervisor’s Communication System Responsibility

13.0 Emergency Response and Rescue Services

13.1 Emergency Notification/Rescue Initiation

13.2 Contractor (Private) Rescue Services Communications

13.3 Non-Entry Rescue

13.3.1 Non-Entry Rescue Equipment

13.4 Entry Rescue

14.0 Training

14.1 CVG Departments Requiring Confined Space Training

14.2 Training Frequency

14.3 Training Topics

14.3.1 OSHA Confined Space Entry

14.3.2 CVG Confined Space Competent Person

14.4 Training Certificates

15.0 Employee Participation/Follow-Up

16.0 Program Review and User Feedback

16.1 Annual

16.2 Post Confined Space Incident

16.3 User and Key Stakeholder’s Feedback

17.0 Permit Required Confined Space Program Appendices

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1.0 Purpose

This document establishes CVG Airport Authority’s (CVGAA) policy for confined space entry. This program has been developed to protect CVGAA employees and contractors from the serious hazards associated with entering and working within confined spaces. All employees and contractors shall implement this program and related procedures when engaging in confined space operation and maintenance activities. Deviations from this plan are not permitted. This plan and previous entries will be reviewed by the Confined Space Safety Committee at a minimum yearly and may be reviewed more often as necessary.

2.0 Scope

This written program applies to both General Industry (1910.146) and Construction Industry (1926 AA) confined space operations performed on CVGAA property.

3.0 Policy Statement

It is the policy of CVGAA to establish programs to protect the safety and health of its employees and to comply with federal and state requirements. This program contains the requirements necessary to regulate entry into confined spaces and to ensure the safety of employees who enter or work in the confined spaces. Only those employees who have been trained on confined space entry procedures are permitted to enter a confined space using these guidelines.

4.0 References

The following regulatory standards and national consensus standards were used in developing this written program:

• OSHA 29 CFR 1910.146 (General Industry)

• OSHA 29 CFR 1926 AA (Construction Industry)

• ANSI Z 117.1-2016 Requirements for Entering Confined Spaces

• NFPA 350-2019 Guide for Confined Space Entry and Work

5.0 Definitions

• Acceptable entry conditions - Means the conditions that must exist in a permit space, before an employee may enter that space, to ensure that employees can safely enter into, and safely work within, that space.

• Atmospheric Tester - A qualified person selected by the employer who tests or monitors a permit space as necessary to determine if acceptable limits are maintained and is able to interpret the results.

• Attendant - An individual stationed outside one or more permit spaces who monitors the authorized entrants and who performs all attendants’ duties assigned in the employer's permit space program.

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

• Air Purifying Respirator - Air purifying respirators (APR) remove contaminants by passing the breathing air through a purifying element.

• Axial Flow Fan - Axial flow fan draws in air and discharge air along the path of the shaft. That is, the air flows in a straight line through the fan.

• Barrier - A physical obstruction that blocks or limits access.

• Blanking or blinding - The absolute closure of a pipe, line, or duct by the fastening of a solid plate (such as a spectacle blind or a skillet blind) 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.

• Bodily Enter - Bodily enters means 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.

• CFM - Cubic Feet per Minute. A scale used to measure air velocity from a forced air blower.

Combustible Gas Indicator (CGI) - Combustible gas indicator’s measure the concentration of a flammable vapor or gas in air, indicating the results as a percentage of the lower explosive limit (LEL) of the calibration gas.

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• Confined space - Is a space that:

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

2. 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

3. Is not designed for continuous employee occupancy, and/or ventilation of the space is lacking or inadequate, allowing for the potential accumulation of toxic air contaminants, flammable, or explosive agents, and/or depletion of oxygen.

• Competent Person - Means one who can identify existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them.

• Controlling Contractor - Is the employer that has overall responsibility for construction activities at a worksite.

• Double block and bleed - The closure of a line, duct, or pipe by closing and locking or tagging two in-line valves and by opening and locking or tagging a drain or vent valve in the line between the two closed valves.

• Designed for Continuous Worker Occupancy - Designed for continuous worker occupancy: Intended as a place of regular work and supplied with ventilation and other conditions necessary to support life.

• Early Warning System - The method used to alert authorized entrants and attendants that an engulfment hazard may be developing. Examples of early-warning systems include but are not limited to: Alarms activated by remote sensors;

and lookouts with equipment for immediately communicating with the authorized entrants and attendants.

• 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 (flow able) 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 a person passes through an opening into a permit-required confined space. Entry includes 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 Employer - Any employer who decides that an employee it directs will enter a permit space. Note: An employer cannot avoid the duties of the standard merely by refusing to decide whether its employees will enter a permit-required confined space, and OSHA will consider the failure to so decide to be an implicit decision to allow employees to enter those spaces if they are working in the proximity of the space.

• Entry Rescue - Occurs when a recue service enters a permit-required confined space to rescue one or more employees.

• Entry permit - The written or printed document that is provided by the employer to allow and control entry into a permit 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 and overseeing entry operations, and for terminating entry as required by this section. Note: An entry supervisor also may serve as an attendant if that person is trained and equipped as required by this section for each role he or she fills. In addition, the duties of an entry supervisor may be passed from one individual to another during an entry operation.

• Evacuation - An unaided emergency exits out of the confined space. This action may be the result from the entrant’s own decision or by a command from outside the space.

• Full Body Harness (FBH) - Full body harnesses distribute fall arrest forces across the shoulders, upper thighs, chest, and pelvis. Fall arrest harnesses feature a dorsal D-ring for attaching to the connector such as a lanyard and may have other D-rings for use in worker positioning, travel restraint, retrieval or ladder climbing. They are the only form of body support acceptable for fall arrest and should be selected based on the job task as well as the work environment.

• 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 permit space), injury, or acute illness from one or more of the following causes:

1. Flammable gas, vapor, or mist more than 10 percent of its lower flammable limit (LFL). Note for the purpose of the program the terms LFL and LEL are the same.

2. Airborne combustible dust as a concentration that meets or exceeds its LFL; this concentration may be approximated as a condition in which the dust obscures vision at 5 feet (1.52 m) or less.

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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 in

Subpart G, Occupational Health, and Environmental Control, or in Subpart Z, Toxic and Hazardous Substances, of this part and which could result in employee exposure in excess of its dose or permissible exposure limit. An atmospheric concentration of any substance that is not capable of causing death, incapacitation, impairment of ability to self-rescue, injury, or acute illness due to its health effects is not covered by this provision.

5. Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in Subpart G, Occupational Health, and Environmental Control, or in Subpart Z, Toxic and Hazardous Substances, of this part and which could result in employee exposure in excess of its dose or permissible exposure limit. An atmospheric concentration of any substance that is not capable of causing death, incapacitation, impairment of ability to self-rescue, injury, or acute illness due to its health effects is not covered by this provision.

6. Any other atmospheric condition that is immediately dangerous to life or health (IDLH). NOTE: For air contaminants for which OSHA has not determined a dose or permissible exposure limit(PEL-TWA), other sources of information, such as Safety Data Sheets(SDS), Threshold Limit Value(TLV) from the American Conference of Industrial Hygienists(ACGIH) that comply with the OSHA Hazard Communication Standard, NIOSH published information, and internal documents can provide guidance in establishing acceptable atmospheric conditions.

• Host Employer - The employer that owns or manages the property where the construction work is taking place.

• Hot work permit - The employer's written authorization to perform operations (for example, riveting, welding, cutting, brazing, 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. Note: Some materials-hydrogen fluoride gas and cadmium vapor, for example-may produce immediate transient effects that, even if severe, may pass without medical attention, but are followed by sudden, possibly fatal collapse 12-72 hours after exposure. The victim "feels normal" after recovery from transient effects until collapse. Such materials in hazardous quantities are "immediately" dangerous to life or health.

• Inerting - The displacement of the atmosphere in a permit space by a noncombustible gas (e.g., nitrogen) to such an extent that the resulting atmosphere is noncombustible.

• Intrinsically Safe - A designation on the manufacturer’s label placed on equipment, indicating that it is designed to be safely used for a specific hazard or within a specific kind of confined space. Note all air monitors, flashlights, and/or radios shall be Intrinsically safe so as not to cause a spark or static discharge in a possible combustible atmosphere.

• 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 by such means as: blanking or blinding, misaligning, or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.

• Lower Explosive Limit (LEL) - The concentration of flammable vapors in the air is below a level which will result in a flame, given an ignition source. Note: OSHA LEL alarm standards for Confined Spaces is 10% of the LEL.

• Limit or Restricted Means of Entry or Exit - Any space where an occupant must crawl, climb, twist, be constrained in a narrow opening, follow a lengthy path, or otherwise exert unusual effort to enter or leave, or where the entrance may become sealed or secured against opening from inside.

• Lockout/Tagout - The placement of a lock /tag on an energy isolation device in accordance with CVG policy.

• Line breaking - The intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure, or temperature capable of causing injury.

• Monitoring - The process used to identify and evaluate the hazards after an authorized entrant enters the space. This is a process of checking for changes that is performed in a periodic or continuous manner after the completion of the initial testing or evaluation of that space.

• Non-entry rescue - Occurs when a rescue service, usually the attendant, retrieves employees from a permit-required confined space WITHOUT ENTERING the permit-required confined space.

• Non-permit Confined Space - A space that by configuration meets the definition of a confined space, but which after evaluation presents no potential or existing serious hazards to the entrants, or has the hazards removed by engineering controls.

• Oxygen deficient atmosphere - An atmosphere containing less than 19.5 percent oxygen by volume.

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• Oxygen enriched atmosphere - An atmosphere containing more than 23.5 percent oxygen by volume.

• Permit-required confined space (permit 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 by a floor which slopes downward and tapers to a smaller cross-section; or

4. Contains any other recognized serious safety or health hazard.

• Permit-required confined space program (permit space program) - The overall (written) program for controlling, and for protecting employees from, permit space hazards and for regulating employee entry into permit spaces.

• Permit system - The employer’s written procedure for preparing and issuing permits for entry and for returning the permit space to service following termination of entry.

• Permissible Exposure Limit (PEL)-TWA – A Permissible Exposure Limit (PEL) is the allowable air contaminant level that a worker may be exposed to under OSHA regulations. A Time-Weighted Average (TWA) is the employee's average airborne exposure in any 8-hour work shift of a 40-hour work week which shall not be exceeded.

• Physical Hazard - An existing or potential hazard that can cause death or serious physical damage. Examples include, but are not limited to:

1. Engulfment

2. Flow Path

3. Hazardous energy releases

4. Falling objectives

5. Interior uneven or wet surfaces

6. Temperature

7. Noise

8. Biological hazards

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

• Qualified Person - One who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.

• Rescue - Assistance in exiting the confined space by providing assistance to the entrant by the rescuer(s) to effect exit from the space.

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

• Retrieval System - Means 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. The retrieval system must be available, meaning that the entrant's retrieval line is attached to a mechanical device so that rescue can begin as soon as the rescuer becomes aware that rescue is necessary.

• Serious Physical Damage - Means an impairment or illness in which a body part is made functionally useless or is substantially reduced in efficiency.

• Shall - Denotes a mandatory requirement.

• Snaphook - Means a connector comprised of a hook-shaped body with a normally closed gate, or similar arrangement that may manually opened to permit the hook to receive an object. When released, the snaphook automatically closes to retain the object. Opening snaphooks require two separate actions. Note: only Automatic -locking snaphooks permitted.

• Supply Air Respirator (SAR) - A supplied air respirator (SAR) is a piece of personal protective equipment (PPE) for workers in an environment where the air is contaminated, harmful or uncomfortable for breathing. This PPE provides breathable air continuously or on pressure demand from either a cylinder or a pipe connected to an airline, compressor, air pumps, air purifier or surface supply hose. The air is delivered to the worker at ambient pressure through a hood, face mask or mouthpiece.

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• Tagout - Placement of a tagout device on a circuit or equipment that has been deenergized, in accordance with an established procedure, to indicate that the circuit or equipment being controlled may not be operated until the tagout device is removed; and We ensure that Tagout provides equivalent protection to lockout; or that lockout is infeasible, and we have relieved, disconnected, restrained and otherwise rendered safe stored (residual) energy.

• 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.

• Vapor Density - The tendency of a gas or vapor to rise or fall in air. Air has a vapor density of 1.0; gases and vapors with vapor densities less than 1.0 will rise in air; those with vapor densities greater than 1.0 will sink in air.

• Ventilation - Controlling a hazardous atmosphere using continuous forced-air mechanical systems that meet the requirements of this program.

6.0 Roles and Responsibilities

6.1 CVG Safety Department

The CVG Safety Department is responsible and accountable for the safety of all CVG employees. This directly relates to safeguarding our employees, the environment, public property, and CVG equipment. The CVG Safety Department provides advice and assistance to CVG management in developing, organizing, directing, and evaluating confined spaces for hazards and appropriate controls. The CVG Safety Department is responsible for administrating this Program. The CVG Safety Department will evaluate/monitor work areas and equipment/tools as required and assist in ensuring that the Program is implemented per OSHA regulations.

6.1.1 CVG Safety Department Responsibilities

• Working with supervisors and employees to identify, develop and implement appropriate controls to mitigate hazards associated with confined space entry.

• Ensuring that appropriate audits and program reviews are conducted in accordance with applicable regulations and standards.

• Develop and maintain a Confined Space Competent Person program.

• Develop and maintain a Confined Space Hot Work program

• Coordinating and delivering training required under this program.

• Ensuring that areas identified as confined spaces are posted with signage as required

• Retain each canceled entry permit for at least 1 year to facilitate the review of the permit-required confined space program annually. Any problems encountered during an entry operation shall be noted on the pertinent permit so that appropriate revisions to the permit space program can be made.

• Reviewing and updating the Confined Space Entry Program annually and after a major confined space incident.

• Function as Host Employer with all Controlling Contractors. Note this responsibility may be delegated in writing to a designated Department Manager who is CVG Confined Space Program Competent Person qualified. Host Employer responsibilities include:

• Provide a copy of the CVG Permit Required Confined Space Program a minimum of 45 days prior to any contractor work operations on CVG property.

• If Controlling Contractor elects to use its own written Confined Space Program. The controlling contractor shall submit a copy of that program a minimum of 30 days prior to the beginning of work operations at CVG. The Safety Department or designated Department Manager, who is Confined Space Competent qualified, is responsible for reviewing and ensuring that the Controlling Contractor’s Confined Space program is compliant with CVG and OSHA Confined Space program requirements.

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6.2 CVG Management and Supervision (Including Leads)

6.2.1 CVG Departmental Managers Responsibilities

• Ensure employees performing confined space entry practice measures to mitigate hazards as described in the permit.

• Ensure that employees receive required CVG and regulatory training and have documented proof of certification from the CVG Safety Department before participating in confined space entry.

• Work with the CVG Safety Department to identify and eliminate hazards when possible and institute appropriate controls prior to confined space entry.

• Ensure the implementation of engineering controls, administrative practices, and/or PPE as necessary including necessary equipment and personnel support.

• Issue and provide oversight of Hot Work Permit’s issued with a Confined Space Entry Permit.

NOTE

Department Managers shall authorize/approve work which requires personnel under their supervision to enter a confined space.

6.2.2 CVG Planning and Development Department Responsibilities

• Assist the CVG Safety Department in identifying and communication of new project work that may create potentially hazardous Permit-required Confined Spaces.

• Participate in the CVG Confined Space Safety Committee.

6.2.3 CVG Construction Inspectors Responsibilities

• Notify CVG Safety Department and the responsible CVG Department or Project Manager of any unsafe conditions observed during their inspections.

6.2.4 CVG Project Managers Responsibilities

• Provide Confined Space regulatory oversight and support to the designated Controlling Contractor and all contractors that are in support of the project(s).

• Work with the CVG Safety Department to identify and eliminate hazards when possible and institute appropriate controls prior to contractor confined space entry.

6.3 Airport Operations Center (AOC) Responsibilities

• Documents and tracks all Confined Space operations conducted on CVG property.

• Coordinates with CS Entry Supervisor.

• Coordinates with the CVG ARFF Department for Confined Space Rescue coverage.

• Monitor CVG Fire/EMS Operations to determine if CVG ARFF has adequate resources for Confined Space Rescue.

If not the AOC shall suspend all ongoing Permit Required Confined Space operations at CVG.

6.4 Airport Rescue and Firefighting (ARFF) Department Responsibilities

6.4.1 Rescue Service and Emergency Services Responsibilities

The CVG Airport Rescue and Firefighting (ARFF) Department is the designated the primary Confined Space Rescue Service for all CVG Permit Required Confined Space activities. Prior to making any confined space entry, the Airport Operations Center (AOC) shall be notified of the confined space entry location, times, and any known hazards. After the confined space entry is complete, the Airport Operations Center (AOC) shall be contacted to advise them the entry is complete. In the event an entry rescue is needed the Entry Supervisor shall call the AOC at (859) 767-3123.

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NOTE

CVG and Contract employees (except for ARFF) are not permitted to enter a confined space for rescue purposes. Exception is a Contractor Rescue Team approved by CVG

Safety & ARFF.

6.4.2 Hot Wok Permits

• Issuing and administratively tracking all “blanket” 6-month Hot Work Permits to all authorized CVG departments and Controlling Contractors in accordance with NFPA 51B and OSHA Welding, Cutting and Brazing safety regulations.

• Provide subject matter expertise and technical assistance for Confined Space Hot Work operations.

6.5 Controlling Contractor Responsibilities

• Develop and submit a Project-based Confined Space program to the CVG Safety department for review and approval

30 days prior to project start on CVG property (refer to 1926 Subpart AA).

• Coordinate entry operations when there is more than one entry employer.

• Coordinate operations when a permit space entry occurs during other activities at CVG that might create other hazards.

• Ensure employees performing confined space entry practice measures to mitigate hazards as described in the permit.

• Ensure that employees receive required CVG and regulatory training and have documented proof of certification from the CVG Safety Department before participating in confined space entry.

• Work with the CVG Safety Department to identify and eliminate hazards when possible and institute appropriate controls prior to confined space entry.

• Ensure the implementation of engineering controls, administrative practices, and/or PPE as necessary including necessary equipment and personnel support.

• Provide oversight of private Confined Space Rescue Teams, for contractors they control, to ensure compliance with this Plan and CVG Airport ARFF rescue procedures.

6.6 Private (Contractor) Confined Space Rescue Teams Responsibilities Contractor Confined Space Rescue Teams shall meet all the training requirements set forth in OSHA regulations 29 CFR 1910.146(k) and 29 CFR 1926.1211. All Contractor Rescue Teams shall be approved by the CVG Safety Department and CVG ARFF prior to assuming rescue duties.

6.6.1 OSHA General Industry Operations

The Entry Team Supervisor along with the overseeing CVG department manager shall ensure the contractor rescue team meets the all the training requirements stated above and that the contractor rescue team meets the rescue equipment requirements stated in the above OSHA regulations. The Entry Team Supervisor will ensure the contractor Rescue Team Leader is knowledgeable on AOC communication procedures.

6.6.2 OSHA Construction Industry Operations

The contractor Entry Supervisor shall coordinate with the Controlling contractor to ensure that contractor rescue team meets both the training and equipment requirements set forth in the above regulations. The Entry Team Supervisor shall ensure that the contractor Rescue Team Leader is knowledgeable on AOC communication procedures.

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7.0 General Requirements

7.1 Scope of Activity between OSHA Construction and General Industry Construction work, as per OSHA 29 CFR 1910.12(b) means work for construction, alteration, replacement of equipment with a newer or upgrade model, and/or repair (major or significant upgrade) or decorate. Construction work involving confined spaces shall be in accordance with OSHA 29 CFR 1926 Subparts AA and the CVG Permit Required Confined Space program.

General Industry work means under these regulations CVG day-to-day operations that fall under the General Industry standards until you begin to renovate, repair, or even decorate, then if the stricter rule is under 29 CFR 1926, it is considered construction work. All General Industry work involving Confined Spaces shall be in accordance with OSHA 29 CFR 1910.146 and the CVG Permit Required Confined Space program.

7.2 Confined Space Identification

Employees’ ability to recognize confined spaces and permit required confined spaces is the initial step to provide a safe work environment and to prevent employees from accidentally entering a permit space. OSHA has defined a confined space as a space that has all the following conditions:

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

• Has limited or restricted means for entry or exit (e.g., tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry)

• Is not designed for continuous employee occupancy Once determined to be a confined space, a space would be a permit required confined space based upon the OSHA definition of:

• 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 by a floor which slopes downward and tapers to a smaller cross-section

4. Contains any other recognized serious safety or health hazard

Employees conducting operations involving possible confined spaces should use these definitions and the Confined Space Entry Decision Diagram located in Appendix A when necessary to evaluate whether the activity involves a permit required confined space and institute appropriate health and safety measures.

Examples of confined spaces routinely encountered in industry include, but are not limited to:

• Storage tanks

• Baghouses

• Water tanks

• Excavations/trenches

• Sewers

• Boilers

• Crawl spaces

• Furnaces

• Silos

• Manholes (utility access holes)

• Pipelines

• Elevator pits, tunnels and tank cars

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If this document is printed, it is uncontrolled; refer to CVGAA Hub/Policies, Rules and Regulations for the official, most recent version.

Activities which may be conducted in confined spaces include, but are not limited to:

• Cleanup

• General maintenance

• Repair

• Instrument installation/removal

• Welding/burning

• Painting

• Inspections

• Sample collection

7.3 Non-Permit Confined Space

All confined spaces as defined and associated located on CVG property are designated permit-required confined spaces.

CVG Confined Space qualified employees and qualified contractors are required to assess the Confined Space using the Confined Space Reclassification Procedures Form located in Appendix E. Newly created confined spaces; CVG or contractor qualified confined space Competent Person’s shall use the Confined Space Survey form located in Appendix B, Annex 1.

7.3.1 Safe Work Procedures (SWP)

SWP shall be developed and implemented for all Non-Permit Confined Spaces located on CVG property. The objective of these SWPs is ensure safe conditions and precautions are in place for safe entry and what constitutes a change in conditions which would require re-evaluation of the confined space.

7.4 Preventing Unauthorized Entry

7.4.1 Signage

To inform employees, contractors, and visitors of the existence of a permit space at CVG facilities, permit spaces shall be posted with danger signs reading "DANGER - PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER" or similar language. The sign should be posted in a conspicuous location such that it can be readily seen by any individual who happens upon each access to a permit required confined space.

NOTE

A sign reading "DANGER-PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER" or using other similar language would satisfy the requirement for a sign.

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7.4.2 Access Protection

The attendant shall have primary responsibility to prevent unauthorized person from entering the confined space at the entry access. For other access points, such as those opened to permit ventilation, the following methods can be utilized to limit access of unauthorized entrants to a confined space at these points. This is not intended to be a complete list as there are other ways to accomplish protecting the access to confined spaces.

• Station a worker at each entry/access point to inform unauthorized Entrants of the space and the prohibition against entering.

• Close off each entry point by reattaching the access cover if unattended.

• Secure a substantial barrier (expanded metal wire, etc.) to each access point that is unattended.

7.4.3 Reporting Unauthorized Entry or Attempts to Entry

Any unauthorized entry or attempted entry must be reported to the Entry Supervisor immediately. The Entry Supervisor is responsible for removing unauthorized individuals who enter or who attempt to enter the space during entry operations.

However, attempts should be made to deter the unauthorized person from entering the space. This should be done verbally. Bodily force should not be used.

7.5 Confined Space Survey

The Confined Space Survey is required for Confined Spaces located on CVG Property (refer to Appendix B Annex 1).

A confined space survey is performed by a confined space Competent Person who is knowledgeable with the facility or project site. The Controlling Contractor shall provide oversight to ensure the Contractor Competent Person is both qualified with OSHA Confined Space survey requirements and this document. Contractors using their own Confined Space Survey form shall have that form reviewed and approved by their CVG Project Manager or CVG Safety Department prior to use.

The following is identified on the survey:

• Name or description of the confined space.

• Building, area, room, or other location of the confined space.

• Permit or non-permit required confined space.

• Known or potential hazards present in the confined space including:

1. Oxygen deficient or enriched atmosphere

2. Flammable/explosive atmosphere

3. Toxic atmosphere

4. Mechanical hazards

5. Electrical hazards

6. Chemical hazards

7. Biological hazards

8. Fall potential

9. Temperature

• Potential hazards are evaluated for the following prior to approving entry:

1. Magnitude of the hazard

2. Likelihood of occurrence

3. Consequences of the occurrence

4. Potential for changing conditions/activities

5. Strategies for controlling, eliminating, or isolating the hazard; and

6. Impact on emergency response/rescue.

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• Control measures to take prior to entry as defined on the Hazard Survey; and

• Personal protective equipment (PPE) requirements for entry.

7.6 Confined Space Rescue Pre-Planning

CVG Safety Department in cooperation with the CVG ARFF shall coordinate with existing CVG Departments to establish a schedule in creating Confined Space Rescue Pre-Planning for high hazard Permit-required spaces (refer to Appendix C Annex 2).

Contractor Confined Space Rescue Team shall coordinate with the Entry Supervisor to develop a Confined Space Rescue Pre-Plan using the CVG Confined Space Rescue Pre-Plan form (use Appendix C Annex 2 as a guide). That plan will be attached to the CS Entry Permit and be available for inspection by the Controlling Contractor and CVG Confined Space qualified personnel.

7.7 Evaluation of Confined Space Program

Field surveys, Confined Space Entry Program, and cancelled permits are reviewed on an annual basis to determine if any of the confined spaces require a change in status. In order to add, remove or declassify a confined space, the confined space survey guidelines must be followed, the survey updated, and respective confined space entry personnel must receive training on those changes.

8.0 Permit System

Prior to entry into a permit required confined space, CVG employees must have a workorder issue by CVG Management.

The Entry Supervisor then initiate’s the entry permit process. The Entry Supervisor shall obtain a blank permit and permit identification number (option is to use the workorder number). The Entry Supervisor should also review; the Confined Space Survey (refer to Appendix B Annex 1) and any available prior permits issued for the space to assist in hazard assessment of the space. All items must be reviewed, evaluated, and performed before the Entry Supervisor; approves the permit, signs the permit, indicating all information is complete, accurate and safe entry conditions have been met.

8.1 No Entry

When planning a confined space entry, one option to consider is NO ENTRY. This option may be viable with a little adaptation to the operation and should be considered before a decision to enter is made.

8.2 Confined Space Entry Permit (Refer to Appendix C)

The confined space entry permit documents compliance with OSHA regulations in (1910.146 and 1926 Subparts AA) and authorizes entry to a permit space. Contractors using their own Confined Space Entry Permit shall ensure their permit meets the following information requirements.

8.2.1 Confined Space Permit Form Information Requirements

• The permit space to be entered.

• The purpose of the entry.

• The date of the entry permit.

• The authorized entrants within the permit space, by name or by such other means (for example, through the use of rosters or tracking systems) as will enable the attendant to determine quickly and accurately, for the duration of the permit, which authorized entrants are inside the permit space.

• The personnel, by name, serving as attendants.

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

• The hazards of the permit space to be entered.

• The measures used to isolate the permit space and to eliminate or control permit space hazards before entry such as the lockout or tagging of equipment and procedures for purging, inerting, ventilating, and flushing permit spaces.

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• The acceptable entry conditions.

• The results of initial and periodic tests performed and an indication of when the tests were performed.

• The rescue and emergency services that can be summoned and the means (such as the equipment to use and the numbers to call) for summoning those services.

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

• Equipment, such as personal protective equipment, testing equipment, communications equipment, alarm systems, and rescue equipment, to be provided.

• Additional information whose inclusion is necessary, given the circumstances of the confined space, to ensure employee safety.

• Any additional permits, such as for hot work, which have been issued to authorize work in the permit space.

NOTE

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 so that the entrants can confirm the information.

8.3 Entry Supervisor

The Entry Supervisor is a competent person assigned to supervise the confined space entry and is responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry, overseeing entry operations, and for terminating entry as required by this section.

8.3.1 Entry Supervisor Responsibilities

• Reviews, understands, and knows the hazards faced during entry - including the chemical (i.e., SDS, mode, signs or symptoms and consequence of exposure to chemical substances, etc.) and physical hazards of the space.

• Determines if acceptable entry conditions are present at a permit space where entry is planned

• Before permitting entry, reviews and prepares the Entry Permit to verify the following:

1. All entries are properly recorded on the permit.

2. All tests specified by the permit have been conducted including any needed atmospheric testing

3. All appropriate equipment, PPE and procedures specified by the permit are in place.

4. Assigns employees to fill the duties of Attendant and Entrant.

5. Verifies that rescue services are available and that the means for summoning or enacting them are operable. This includes maintaining continuous communication contact CVG Airport Rescue and Firefighting (ARRF) Department.

• Completes the Confined Space Entry Supervisor Checklist form (refer to Appendix C Annex 1)

• If applicable. Completes the Confined Space Entry Supervisor Hot Work Checklist as part of Safe Entry Conditions

(refer to Appendix J)

• Conducts pre-entry safety meeting including assuring all participants are familiar with emergency procedures and their assigned responsibilities.

• Posting of the authorized permit at the space entry or other equally effective means to permit entrants to review the permit.

• Removes unauthorized individuals who enter or who attempt to enter the permit space during entry operations.

• Assures that the entry operation remains consistent with the terms of the permit and that acceptable entry conditions are maintained when entry responsibilities are transferred and at intervals dictated by the hazards and operations performed within the space.

• Coordinates multiple entrant operations when CVG employees and non-CVG employees (e.g., contractors) are working in proximity within or near confined spaces.

• Assures that the communication system is established.

• Maintains situational awareness with the CVG AOC on ARFF capability (units available) to conduct entry rescue.

• Ensures rescue services are available in the event that non entry rescue fails.

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• Terminates the entry and cancels the entry permit under the following conditions:

1. The entry operations covered by the permit are complete and all entrants have left the space, and the space is secured

2. A condition not specified or allowed by the permit arises in or near the permit space

3. Symptoms of hazardous material exposure such as dizziness, blurred vision, tunnel vision, ringing in the ears, nausea, drowsiness, irritation of mucous membranes, or shortness of breath are recognized.

• Notifies the CVG Safety Department and Department (or Project) Manager of any unusual events, i.e., site problems, accidents, injuries, exposures, near misses, changes in tasks, unauthorized entries, or attempts, etc. that occur during the entry operation.

• Before entry begins, the entry supervisor identified on the permit shall review, approve and sign the entry permit to authorize entry.

• Returns any completed/terminated entry permit to the; crew leader, supervisor, manager, supervisor, project manager or designated person responsible for the space and forward a copy to the CVG Safety Department for record keeping and review.

8.3.2 Assumption of Other Duties/Entry by the Entry Supervisor

An entry supervisor may serve as an attendant or as an authorized entrant if that person is trained and equipped as required by this section for each role he/she fills.

The Entry Supervisor can serve dual roles of the Entry Supervisor and attendant as long as the individual’s duties as an Entry Supervisor do not interfere with his/her primary duty as an Attendant.

NOTE

The dual role function is NOT Permitted when operating in an IDLH permit space.

If the entry supervisor enters the permit space, the supervisor must first verify that adequate rescue services are available, that the means for summoning them are operable, and the attendant is knowledgeable on the method to summon rescue if the need arises. The Entry Supervisor must also be listed as an Entrant on the permit for the times in the space.

8.3.3 Transfer of Duties

The duties of entry supervisor may be passed from one individual to another during an entry operation. In this case, a new permit is not required if the replacement supervisor is a qualified Entry Supervisor and his/her name is noted on the established permit. When transferring duties, the oncoming Entry Supervisor shall verify that the entry operation remains consistent with the terms of the permit and that acceptable entry conditions are maintained and signs the permit as the Entry Supervisor.

8.3.4 Coordination with Non-CVG Employees/Contractors

If non-CVG personnel are conducting…