Purpose: To establish and communicate the minimum safety expectations for entering and working in confined spaces while working with Reedy Creek Energy Services (RCES). A confined space has a limited or restricted means of entrance/egress, is large enough and so configured that a worker can bodily enter and perform assigned work, and is not designed for continuous human occupancy.

Who Needs to Know: All contractors / operating partners working in or near confined spaces while working with RCES.

Hazard Severity Ranking: A hazard is a condition or practice with the potential to cause harm. Hazards classified as H4/H5 are those with high severity that have the potential to cause a fatality, total disability, dismemberment, and life-altering changes that are typically irreversible unless all proper precautions are taken.

Standards: Performing work in a confined space shall meet or exceed the requirements of 29CFR1926.1200 – Subpart AA – Confined Spaces in Construction.

Critical 29 CFR 1926 Elements: (The designation of certain requirements as critical does not alleviate the Contractor from complying with ALL applicable aspects of 29CFR1926)

1. Contractors shall determine what kinds of spaces their employees will be in, what hazards could be there, and how those hazards will be mitigated.

2. Alternate entry procedures or reclassification may be used if all requirements of 29CFR1926.1200 are met.

3. Each employee whose work is regulated by this standard shall have proper training. Training shall be in a language and vocabulary that the employee understands.

4. Contractor shall have a written confined space program that meets OSHA requirements for employees that will enter permit-required confined spaces (PRCS).

5. Effective steps shall be taken to prevent employees from entering PRCS, if employees will not need to enter those spaces.

6. General contractor shall coordinate entry activities with both RCES and sub-contractors.

7. Contractor(s) shall have a competent person to evaluate the site and identify and classify confined spaces. The competent person shall be able to recognize those conditions that require a confined space permit:

• Contains, or has the potential to contain, a hazardous atmosphere

• Contains a material that has a potential for engulfing the entrant

• 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

• Contains any other recognized serious safety or health hazard

8. Provide continuous atmospheric monitoring and continuous monitoring of engulfment hazards during entry.

9. Contractor must have a rescue plan that meets the requirements established by 29 CFR 1926.1200. Contractor shall arrange for rescue and emergency services for employees who enter PRCS.

HAZARD SEVERITY

H-4/H-5Contractor Safety Expectation

Confined Spaces 3/13/2018

• If relying on the local fire department for emergency services, the contractor shall arrange for the fire department to provide advance notice if they will be unable to respond for a period of time.

RCES Clarifications and Additional Requirements:

1. Contractors, including subs, will have a written confined space program when performing PRCS entry at RCES. Site specific conditions related to confined space entry must be addressed in the Project Specific Safety Plan (PSSP).

2. Contractors and subs shall provide their own confined space permits when working with RCES.

3. All workers entering a confined space must have training commensurate with the role or task they will be performing.

This includes:

• Entrant

• Attendant

• Entry supervisor

• Air monitoring

• Rescue

• Site-specific training for workers exposed to hazards posed by PRCS, but not performing work inside of confined space or supporting confined space entry

4. Confined spaces that have been evaluated and designated by RCES as permit required will be treated as such even if contractor disagrees with that designation. Trenches may be treated as confined spaces under certain conditions.

Alternate entry procedures or reclassification may be used if all requirements of 29CFR1926.1200 are met.

5. When certain conditions described in the OSHA standard are met, the employer may use alternate entry procedures for worker entry into a permit space. RCES must be involved in the decision to use alternate entry procedures.

6. RCES is responsible for providing information to Contractor on any known hazards associated with the space.

7. RCES is NOT responsible for providing additional services during entry, including but not limited to:

• Atmospheric monitoring

• Emergency response services including rescue

• Attendants or Entry Supervisors

8. All equipment for atmospheric monitoring must be calibrated according to manufacturer’s recommendations prior to use and must, at a minimum, test for oxygen deficiency and enrichment, flammable gases, hydrogen sulfide and carbon monoxide. Any other known or suspected atmospheric hazard must also be tested for prior to and during entry.

9. Atmospheric monitoring equipment will, at a minimum, have alarms set for the 8-hour time-weighted average (TWA) and short term exposure limit (STEL). Monitors shall have simultaneous and multiple alarm indicators, such as audible, visible and/or vibrating alarms to indicate hazardous conditions.

10. Atmospheric testing must be conducted prior to any attempt to ventilate the space and before entry. Monitoring shall be conducted every four feet to detect any possible layers or areas with higher vapor concentration than the rest of the space.

11. Ventilation may be utilized to control hazardous atmospheres and maintain acceptable entry conditions. General dilution ventilation and/or local exhaust ventilation may be used to maintain acceptable entry conditions, as verified by monitoring.

12. No one shall enter a confined space to attempt rescue unless they have been trained and equipped for confined space rescue operations. If it can be performed safely, attendants will only use non-entry rescue techniques to perform rescue if they have been trained to do so.

13. Spaces that have an internal configuration that would prevent non-entry rescue shall have a rescue plan. Entry rescue will be only performed by a rescue team able to perform the responsibilities and meet the qualifications outlined in the OSHA standard. Most contractors will not have the capability to perform entry rescue; they will have to partner with an outside organization to provide rescue. The rescue team must have the proper training and equipment and be available to respond in a timely manner.

14. RCES reserves the right to stop work being performed and remove contractor personnel from a confined space if an unsafe condition or behavior is observed. The space will be evacuated until concerns are resolved.

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15. Contractors will debrief RCES about any hazards encountered or created during the confined space entry by either themselves or their subs.

Revision History

Rev Description of Change Owner Effective Date

0 Preliminary Draft N/A 2017 Nov 09

A Updated to reference RCES Manager, Utility Integration

2018 Jan 30

B Changes based on review and comments from RCID Manager, Utility Integration

2018 Mar 13